The U.S. IRS has published the bilateral competent authority arrangement signed with South Korea on the exchange of Country-by-Country (CbC) reports. The agreement was signed 22 June 2017 and is effective from that date. The arrangement provides that pursuant to the provisions of Article 28 (Exchange of Information and Administrative Assistance) of the 1976 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 the CbC report, one or more constituent entities of...