The U.S. IRS has published the bilateral competent authority arrangement signed with Australia on the exchange of Country-by-Country (CbC) reports. The agreement was signed by Australia and the U.S. on 14 July and 1 August 2017, respectively, and is effective from the later date of signature. The arrangement provides that pursuant to the provisions of Article 25 (Exchange of Information) of the 1982 income tax treaty between the two countries, each competent authority will automatically exchange CbC reports received from each reporting entity resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in...