This section presents all the bilateral exchange relations currently under way for the automatic exchange of information on IRS, in accordance with Article 6 of the Multilateral Convention and the CRS-MCAA, as well as within the framework of the EU. In addition, some legal systems have bilateral IRS information exchange agreements under bilateral tax treaties or tax information exchanges. In August 2020, more than 2,500 bilateral exchanges were activated for jurisdictions that committed to exchange CBC reports, and the first automatic exchange of CBC reports took place in June 2018. These include exchanges between the signatories of the Convention on Multilateral Competent Authorities (CBC MCAA), between eu Member States, in accordance with the EU Directive 2016/881/EU, and between signatories of bilateral agreements for the exchange of competent authorities under double taxation agreements or exchange of tax information, including 41 bilateral agreements with the United States. Legal systems continue to negotiate CBC reporting agreements and the OECD will issue regular updates to clarify things for MNE groups and tax administrations. Since more than 100 legal systems have committed to exchange information within the IRS, exchanges between legal systems are generally based on the multilateral convention on mutual tax assistance (convention), in which more than 100 jurisdictions participate, and the Multilateral Competent Authority`s (CRS MCAA) IRS Convention (CRS MCAA), which is based on Article 6. Legal systems can be based on a bilateral agreement, such as a double taxation agreement or an agreement on the exchange of tax information. In addition, some IRS exchanges will be organised on the basis of the relevant EU directive, agreements between the EU and third countries and bilateral agreements such as the agreements between the UK and the CDOT. Peru is taking important steps to combat corruption and promote greater transparency and information exchange by taking the necessary steps to engage in the OECD Convention on Combating Corruption of Foreign Officials in International Trade Transactions (Anti-Corruption Convention) and the Multilateral Convention on Mutual Tax Assistance. The CRS MCAA provides details of the information that will be exchanged and when. It is a multilateral framework agreement. A specific bilateral relationship under the MCAA CRS only comes into force when the two jurisdictions have implemented the convention, submitted the necessary notifications in accordance with Section 7 and presented themselves to each other.
The objective of the CBC MCAA is to establish the necessary rules and procedures for the relevant AUTHORITIes of BEPS 13 to implement the cbC reports prepared by the reporting unit of an MNE group and submitted annually to the tax authorities of that unit with the tax authorities of that entity.