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Diane Ringtaxes). 4 Thus, BEPS problems can be particularly significant for thesejurisdictions. The costs of BEPS to developing countries may be moresevere and the impediments to overcoming BEPS may also be greaterfor these jurisdictions. Developing countries may experience a numberof hurdles in securing information, transparency and disclosure frommultinational businesses. A review of these barriers directs attentionto the changes that may be needed and allows reform proposals to bemeasured against the list of challenges so as to see where and to whatextent such proposals can help. The impediments can be grouped intoroughly three categories: (a) domestic law; (b) domestic enforcement;and (c) international support.2.2.4.1 Domestic law impedimentsSome countries already have in place domestic law reporting requirementsthat provide relevant taxpayer information. Such reportingrequirements can include the obligation of the taxpayer to provideinformation regarding: (a) foreign related entities and related-partytransactions; (b) foreign financial assets and accounts; (c) discrepanciesbetween tax reporting and accounting treatment; and (d) certainkinds of tax shelters or otherwise suspect transactions and structures.This information can be useful in helping a country determine whetherto initiate an audit, and where and how to direct its attention in anaudit. If a developing country does not have such reporting regimesin place, changes to domestic law reporting requirements may be onestep in the process of enhancing transparency and disclosure. Thefinal recommendations that ultimately emerge from the OECD projecton BEPS regarding Actions 12 and 13 in the OECD Action Plan mayplay a guiding role for countries that are just starting to institute suchreporting requirements (see sections 3.4 and 3.3 below, respectively).The work of the Global Forum on Transparency and Exchangeof Information for Tax Purposes (Global Forum) identifies otherfundamental domestic law features that can inhibit (or conversely,facilitate) transparency. The peer review process of the Global Forum4See, for example, OECD, Part I of the Report to G20 Development WorkingGroup on the Impact of BEPS in Low Income Countries (Paris: OECD, July2014), at 11, available at http://www.oecd.org/tax/part-1-of-report-to-g20-dwg-on-the-impact-of-beps-in-low-income-countries.pdf.502