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Hugh J. Ault and Brian J. Arnoldraises similar questions of characterization. In some cases, it might bepossible to treat such situations as involving royalties or rentals, thustypically giving taxing jurisdiction to those countries that follow theUnited Nations Model Convention’s approach to royalties.5.4 OECD Action 1 — 2014 DeliverableThe OECD issued a report in 2014 entitled “Addressing the TaxChallenges of the Digital Economy.” 16 The report discusses manyof the issues raised in the previous sections but makes no specificrecommendations.6. Transparency and disclosure6.1 GeneralIn order to assess the extent of possible base erosion and profit shifting,it is essential that tax authorities in developing countries have accessto information about the nature and structure of the activities of taxpayerscarrying on business or investing in their jurisdiction. Thisrequires both transparency with respect to the way in which taxpayers’activities are structured and disclosure of the necessary information.The information involved may be detailed information as to particulartransactions (for example, the determination of transfer pricing) ormore general, higher-level information that allows the tax authoritiesto view the overall structure of the taxpayer’s global business and, inparticular, the use made of tax haven vehicles as part of a tax avoidancescheme. These matters primarily concern MNEs doing businessand investing in the country. The primary function of transparencyand disclosure in this context is to help jurisdictions to assess and collectthe appropriate amount of tax on inward investment. The underlyingtax issues concerned arise principally in the context of transferpricing and base-eroding payments. The OECD Action Plan on BEPSis primarily focused on these matters.16OECD/G20 Base Erosion and Profit Shifting Project: Addressing the TaxChallenges of the Digital Economy — Action 1: 2014 Deliverable (Paris: OECD,2014), available at http://www.oecd.org/tax/beps-2014-deliverables.htm.22