IRS Publishes Model Competent Authority Arrangement for Exchange of CbC Reports based on Mutual Assistance Convention
The U.S. IRS has published the model competent authority arrangement for the exchange of Country-by-Country (CbC) reports on the basis of the Convention on Mutual Administrative Assistance in Tax Matters. Although based on the multilateral Mutual Assistance Convention, the competent authority arrangement is still bilateral in nature; between the U.S. and the respective counterparty to the arra…
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