The Federal Tax Service of Russia
Published: 07.02.2017 15:52
On January 26, 2017 the Russian Federation signed the multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA). Full list of signatories can be found at http://www.oecd.org/tax/automatic-exchange/about-automatic-exchange/CbC-MCAA-Signatories.pdf.
The purpose of the CbC MCAA is to set forth rules and procedures necessary for jurisdictions to implement automatic exchange of CbC Reports prepared by multinational enterprise groups. This mechanism is envisaged by Action 13 of the Base Erosion and Profit Shifting Action Plan (BEPS).
The CbC MCAA is based on Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters. The Convention is applicable for the Russian Federation since July 1, 2015. As of January 3, 2017 108 jurisdictions participate in the Convention. This represents a wide range of countries including all G20 countries, all BRIICS, all OECD countries, major financial centres and an increasing number of developing countries. A full list of participating jurisdictions can be found at http://www.oecd.org/ctp/exchange-of-tax-information/conventiononmutualadministrativeassistanceintaxmatters.htm
On May 12, 2016 the Russian Federation already signed the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (CRS MCAA) which is also based on the Convention. The CRS MCAA is a multilateral framework agreement which specifies the details of what information will be exchanged and when. A current list of CRS MCAA signatories is available at http://www.oecd.org/tax/automatic-exchange/international-framework-for-the-crs/
Among early adopting countries the first exchanges under the CRS MCAA and CbC MCAA will start in 2017. Russia has made a commitment to start automatic exchange of information in 2018.