Stack says US will withdraw CbC information if made public

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Stack says US will withdraw CbC information if made public

The US will not share country-by-country report (CbCR) information with foreign authorities who choose to make the reports public, said deputy assistant secretary at the US Treasury Robert Stack.

Joelle Jefferis

Stack was speaking at the Irish Tax Institute and the Ash Center at Harvard Kennedy School’s Global Tax conference in Dublin.

Last week Stack said that he “fully expects” the US to have finalised its CbCR provisions by July this year. At the conference he reiterated his country’s commitment to implementing CbCR, but warned the US wouldn’t exchange information if a country intends to make it public.

“In the US there will be no stepping back from CbCR,” said Stack, but continued with a warning: “If a country were to make that information public, the US would have the right in our agreements to stop sending that information.”

Stack had earlier in the day spoken on another panel with Valere Moutarlier, director of the Directorate General for Taxation and Customs at the European Commission (EC). Moutarlier had mentioned that the EC are reviewing whether to publish CbC reports, with the proposal on this due to be released in April.

“We resisted heavy pressure from many quarters to rush on this proposal and we’ve taken our time to find the right balance between a high degree of public transparency and protecting the competitive interest of companies,” said Moutarlier.

Tensions surrounding taxation have been growing in recent months between the US and the EU, particularly with the EC’s state aid investigations. Stack has publically condemned the state aid investigations as unfairly targeting US multinationals, but also highlighted at the conference that tensions were created by the view that a major driver of the BEPS project is to attack US multinationals.

So long as the EC doesn’t aim to publish the information, Stack remains hopeful that CbCR will be an effective tool and of use to the US and the EU.

“Companies appreciate that CbCR is a win for the long term. There will be an uneven period while we get on the track but I do expect the whole world to get on track,” said Stack. 

more across site & shared bottom lb ros

More from across our site

AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool
Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025
The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR
Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed
The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
The UK accountancy firm’s transfer pricing lead tells ITR about his expat lifestyle, taking risks, and what makes tax cool
Dolphin Drilling intends to discuss the final liability amount and manner of settlement with HM Revenue and Customs
Gift this article