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Hugh J. Ault and Brian J. Arnoldbasis to other countries (that is to say, without the need for a specificrequest). Under a mandate from the G20, the OECD has developeda Common Reporting Standard (CRS) establishing the informationto be reported and a Model Competent Authority Agreement (CAA)outlining the mechanism for implementing the exchange. The CRSidentifies the entities that are required to report, the type of informationto be reported and collected and the kinds of accounts on whichreporting is necessary. It is accompanied by a Commentary, which setsout the information technology modalities allowing the informationto be transmitted automatically. Under the CAA, participating countrieswould agree to pass the necessary domestic legislation in order toobtain the required information and to have appropriate safeguards toensure the confidentiality of taxpayer information.6.4 Developing country perspectiveWhile the automatic exchange of information can enhance therevenue-raising capacity of a developing country, there are someimportant technical and policy issues that must be faced. The currentCAA model for exchange of information is structured on the basis ofreciprocity — that is to say, both jurisdictions must be able to obtainand exchange the required information. However, developing countriesmay lack the legal and administrative capacity to obtain informationfrom their local financial institutions. They would not be in a positionto obtain information to exchange, but would be very interested inreceiving information from an exchange partner (for example, froma financial centre). It might be possible to develop some form of“phased in” implementation so that developing countries could benefitfrom obtaining information from other countries while developingtheir own capacity to provide information. A second problem is thatmany developing countries have a limited network of tax treatiesor tax information exchange agreements, which are a condition forand the mechanism for exchanges of information. One possibility forextending the range of automatic exchange would be to take advantageof the Multilateral Convention on Mutual Administrative Assistancein Tax Matters. A number of countries have taken advantage of themechanism, though it remains to be seen exactly how effective it will be.26