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U.S. Publishes CbC Exchange Arrangement with Brazil

04 August 2017

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Treaty Development

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United States-Brazil

The U.S. IRS has published the bilateral competent authority arrangement signed with Brazil on the exchange of Country-by-Country (CbC) reports. The agreement was signed 20 July 2017 and is effective from that date. The arrangement provides that pursuant to the provisions of Article I (Scope of the Agreement) of the 2007 tax information exchange agreement 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 the CbC report, one or more constituent entities of the MNE...