According to an IRS announcement on its website, it has signed separate agreements with the Czech Republic, Finland, Greece, Italy, and Sweden to exchange country-by-country reports on multinationals.
Country-by-Country reporting data will be exchanged pursuant to bilateral Competent Authority Arrangements (CAAs), which rely on Double Taxation Conventions, Tax Information Exchange Agreements, or the Convention on Mutual Administrative Assistance in Tax Matters that permit automatic exchanges of information. The bilateral competent authority agreements would help put into effect 2015 OECD/G20 base erosion profit shifting (BEPS) plan agreements designed to give tax authorities a better picture of the tax affairs of multinational firms.
The Competent Authorities intend to exchange the CbC Reports automatically through a common schema in Extensible Markup Language (XML).