Common Contracts

ARRANGEMENT BETWEEN THE COMPETENT AUTHORITY OF THE UNITED STATES OF AMERICA AND THE COMPETENT AUTHORITY OF THE REPUBLIC OF KOREA

Arrangement on the Exchange of Country-by-Country Reports • June 22nd, 2017

• Contract Type
  Arrangement on the Exchange of Country-by-Country Reports
• Filed
  June 22nd, 2017

Whereas the United States of America and the Republic of Korea desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country‐by‐country reports (“CbC Reports”), with a view to assessing high‐level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;