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.