The U.S. IRS has published the competent authority arrangement on the exchange of Country-by-Country (CbC) reports with Portugal. The arrangement was signed 2 October 2017 and is operative (effective) from that date. The arrangement provides that pursuant to Article 28 (Exchange of Information) of the 1994 Portugal-U.S. income tax treaty, 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 constituent entities of the MNE group of the reporting entity are resident for...