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 arrangement. The model arrangement can be used in cases where the automatic exchange of CbC reports would not possible under an existing tax treaty or tax information exchange agreement (TIEA), or where no treaty/TIEA is in place. The model arrangement provides that pursuant to...