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Hugh J. Ault and Brian J. Arnoldin the Communiqué resulting from that meeting. 8 An additional setof reports and recommendations on the remaining action items areexpected to be issued by December 2015.1.3 Developing country perspectivesWhile the work of the OECD is important, and substantial efforts weremade to take the viewpoints of developing countries into account informulating its analysis, it was clear from the beginning that somekind of independent examination of the problems of tax avoidanceand the resulting profit shifting and base erosion from the perspectiveof developing countries was required. This is true for a number ofreasons. First, most developing countries are primarily (though notexclusively) concerned with the reduction in source-based taxation,rather than the shifting of domestic income of locally owned companiesto low- or no-tax jurisdictions. Second, the corporate tax oninward investment typically accounts for a greater share of total revenuein developing countries than in countries with more developedtax systems. In addition, the potential responses to base erosion andprofit shifting are limited to some extent by the administrative capacityof developing countries.Protecting the domestic tax base against base erosion and profitshifting is necessary if developing countries are to attain revenuesustainability. Capacity development in this area is essential to movetoward that goal. The OECD work has much to offer to developingcountries in terms of identifying issues and suggesting possible techniquesto deal with the problem of base erosion and profit shifting, butit is important to keep in mind the special needs and perspectives ofdeveloping countries regarding these issues: among others, the state ofdevelopment of the tax system, the administrative resources availableto deal with these matters, the nature of the trade and commercial relationswith trading partners, and regional considerations. Each countrymust evaluate its own situation to identify its particular issues anddetermine the most appropriate techniques to insure a sound tax base.8G20, Leaders’ Declaration, supra note 5, at 20.6