On 27 January 2016, 31 countries -- including Austria -- signed a tax co-operation agreement to enable automatic sharing of country-by-country information. This agreement is a further step towards automatic exchange of information between governments.

The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess  high-level  transfer  pricing  and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Therefore, already the September 2014 Report on Action 13 provided a template for multinational enterprises to annually report specific transfer pricing  information  for  each  tax jurisdiction in which they conduct business. This report is called the  Country-by- Country (CbC) Report. The CbC report is part of a three-tier  structure,  along  with  a "global master file" and  a  "local  file",  which  together  represent  a  standardised approach  to  transfer  pricing  documentation.

The new  Multilateral Competent  Authority Agreement  (MCAA) provides for the automatic exchange of CbC reports. It intends to enable a consistent and swift implementation of the new transfer pricing reporting standards by requiring the signatories to (i) establish the infrastructure for an effective exchange relationship; (ii) provide for the necessary legislation to require companies to file a CbC report; and (iii) safeguard that the information received remains confidential and is only used for purposes of the assessment of transfer pricing risks. It is envisaged that initially the CbC reports will focus on the 2016 accounts. First exchanges on the 2016 information are expected to start in 2017-2018.

The MCAA has been signed by Australia, Austria, Belgium, Chile, Costa  Rica,  the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Japan,   Liechtenstein,   Luxembourg,   Malaysia,   Mexico,   the   Netherlands,   Nigeria,Norway, Poland, Portugal, the Slovak Republic, Slovenia, South Africa, Spain, Sweden, Switzerland and the United Kingdom.