The model arrangements can be found on the US Internal Revenue Service’s website under the Country-by-Country Reporting Guidance.
They include US Model CbC CAA DTC, which is the model arrangement for the exchange of country-by-country reports; and US Model CbC CAA TIEA, which is the model arrangement on the basis of a Tax Information Exchange Agreement for the exchange of country-by-country reports.
Recent Comments
Perhaps have a look at (current) art 2(3)?…
The does not seem correct. All DTAs are about income or capi…
As alluded to above in the post, the relevant non-discrimina…