Kuwait signs OECD multilateral agreements (CbCR-MCAA & CRS MCAA 2.0 Addendum)

Key takeaway

Kuwait has taken a significant step toward deeper alignment with global tax transparency standards by signing two Organization for Economic Co-Operation and Development (OECD) multilateral agreements that expand automatic exchange of information between tax authorities. For multinational groups and financial institutions, this increases the importance of reporting, strong data governance, and consistent cross-border disclosures.

Headed by H.E. the Undersecretary of the Ministry of Finance, Ms. Aseel Suleiman Al Saad Al Muneefi, Kuwait signed the following agreements at the OECD Headquarters in Paris: 

1. Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbCR- MCAA); and 
2. Common Reporting Standards - Multilateral Competent Authority Agreement 2.0 Addendum (CRS MCAA 2.0 Addendum)

The signing of the agreements took place on 28 June 2026 alongside the 7th Peer Review Group meeting of the Global Forum, as Kuwait prepares for its upcoming evaluation on Exchange of Information on Request (EOIR) Standard.

It should be noted that these agreements are within the framework of the Kuwait’s commitment to international standards of tax transparency and combating tax evasion. 

Background:

Country-by-country reporting (CbCR)

Country-by-Country Reporting (CbCR) is a standardized reporting framework requiring large multinational enterprises to disclose key financial and tax information for each jurisdiction in which they operate to enhance transparency and assess tax risks. 

It is one of the minimum standards established by the OECD for Multinationals( MNEs) exceeding annual consolidated group revenue of Euro 750 million or more (or equivalent in domestic currency) in the previous year.

The CbCR MCAA facilitates the automatic exchange of CbC reports among jurisdictions. As of the today, a total of 116 jurisdictions are signatories to CbC MCAA, committed to the automatic exchange of CbC reports.

Why CbCR Exists?

CbCR emerged from Base Erosion and Profit Shifting (BEPS) Action 13 as a tool to enhance tax transparency and identify base erosion risks. OECD Guidelines describe the CbCR as being "helpful for high-level, overview of economic activity among the countries in which Multinational Entities (MNE groups) operate"—enabling tax authorities to have more visibility and transparency over the operation s of MNC Groups.

CbCR can be a starting point for tax authorities as a risk assessment and screening tool for assessing the appropriateness of transfer pricing and is not a substitute for detailed transfer pricing analysis. Tax authorities use it to flag potential BEPS concerns, but any adjustment still requires thorough examination of the underlying transactions.

Further, CbCR enables tax authorities to access aggregated group data (revenue, profit, taxes, headcount, activities) across jurisdictions. As exchange networks expand, inconsistencies between CbCR, transfer pricing documents and policy, and statutory filings become easier to detect.

CbCR data is also crucial in determining if an MNE is eligible for Transitional CbCR Safe Harbor (TCSH) available under the recently introduced Pillar Two regulations in Kuwait.

Common Reporting Standard (CRS)

CRS is a framework for the Automatic Exchange Of Information (AEOI) regarding financial accounts on a global level, between tax authorities, which the OECD developed to combat tax evasion.

The purpose of the signing the CRS MCAA 2.0 Addendum is to enhance international tax transparency and align with OECD standards. It aims to facilitate the automatic exchange of financial accounts information among tax authorities. The addendum introduces expanded reporting obligations, enhanced due diligence procedures and aligns with new financial instruments including crypto-assets and digital financial products.

Why CRS Exists? 

It requires financial institutions (e.g. banks, custodians, certain investment entities/insurers) to: 

• Identify account holders’ tax residency (via due diligence and self-certifications), and
• Report specified account information (e.g., balances, interest, dividends, certain proceeds) to their local tax authority, 

The collected information is then automatically exchanged with the tax authority in the account holder’s country of tax residence.

Why this matters to businesses?

The impact on business from Kuwait signing the CbCR MCAA and the CRS MCAA 2.0 Addendum is mainly that more tax-relevant data will be exchanged automatically with other jurisdictions, increasing transparency and the likelihood that inconsistencies trigger questions, audits, or remediation work. 

Below table summarizes the potential impact of CbCR & CRS for MNEs:

Anticipated Next Steps 

• Watch for ratification and effective dates: Kuwait shall complete internal approval steps and issue guidance on when CbCR exchange and CRS 2.0 requirements become effective (including first reporting/exchange periods and technical formats).
• Expect increased information requests: As Kuwait prepares for OECD/Global Forum peer review, businesses may face more structured and time-bound requests for tax information and supporting documents.

How Deloitte can support?

Our International Tax practice in Kuwait has extensive experience advising multinational enterprises and Gulf conglomerates on treaty-related matters, cross-border structuring, CbCR, CRS and BEPS compliance and advisory related matters.