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Update - U.S. IRS Publishes CbC Exchange Arrangement Signed with Argentina

05 February 2021

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Treaty Development

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United States-Argentina

The U.S. IRS has published the competent authority arrangement on the exchange of Country-by-Country (CbC) Reports with Argentina. The agreement was signed on 27 January 2021 and is operative (effective) from that date. The arrangement provides that pursuant to the provisions of Article 6 (Automatic Exchange of Information) of the 2016 U.S.-Argentina tax information exchange agreement, 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...