On 5 June 2017, the U.S. IRS published the bilateral competent authority agreement on the exchange of Country-by-Country (CbC) reports with South Africa. The agreement as published by the IRS does not indicate the signed date, although according to an update from the South African Revenue Service, it was signed by South Africa on 8 May 2017 and by the U.S. on 26 May 2017. The agreement provides that pursuant to the provisions of Article 26 (Exchange of Information and Administrative Assistance) of the 1997 South Africa-U.S. income and capital tax treaty, each competent authority will automatically exchange CbC reports...