The U.S. IRS has published the bilateral competent authority arrangement signed with the United Kingdom on the exchange of Country-by-Country (CbC) reports. The arrangement was signed on and is effective from 16 August 2017. The arrangement provides that pursuant to the provisions of Article 27 (Exchange of Information and Administrative Assistance) of the 2001 income and capital tax treaty between the two countries, each competent authority intends to 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 the CbC report, one or more...