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Chapter XTransparency and disclosureDiane Ring*1. Introduction1.1 Base erosion and profit shifting and tax informationAcross the globe, countries increasingly express the concern that theyare facing serious financial challenges from base erosion and profitshifting (BEPS). Without a stable and adequate tax base, countrieslose the financial capacity to provide the infrastructure, social servicesand development opportunities important to their citizens. Inresponse, the G20 and the Organisation for Economic Co-operationand Development (OECD) organized the project on BEPS. Much of theproject is focused on substantive law — the rules and practices that canallow the tax base of a country to be eroded and profits to be shiftedout of the country. But the project recognizes that improved substantivetax rules alone are not sufficient to guarantee the tax base of acountry. Without adequate transparency and disclosure of tax informationto the taxing authorities, even the most carefully designed substantivetax rules will fail to protect the base. Thus, an important partof BEPS work targets the more administrative issues of transparencyand disclosure. Ultimately, the goal is to ensure that tax authoritieshave adequate and appropriate access to the information necessaryfor the effective administration of the tax law. As part of this mission,the OECD project on BEPS includes the development of standards forinformation reporting by multinational enterprises — referred to as“country-by-country reporting” (see section 3.3.2 below).1.2 Broader context for tax information issuesBEPS work on transparency and disclosure is not occurring in a vacuum.Existing tools offer tax administrators different avenues for accessing*Professor of Law, Boston College Law School, United States of America.497