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 …