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Transparency and disclosureon the OECD Model Agreement on Exchange of Information on TaxMatters) (see sections 5.2 and 5.3 below). Therefore, the more limitedthe network of bilateral treaties and TIEAs of a country, the more constrainedit may be in gathering needed information. In the same vein,bilateral tax treaties and TIEAs whose terms impose significant barriersto exchange (such as the level of information that the requestermust provide, or the nature of the tax violation in the requesting State)effectively reduce the value of these agreements as meaningful toolsfor developing countries.International mechanisms for sharing information across bordersare important in their own right as independent and currentlyexisting tools for responding to BEPS problems. But the availabilityof these mechanisms may also be important in the future as theOECD project on BEPS moves towards recommendations and action.Depending on how various action items related to transparency, disclosureand information are designed, the ability of a country to benefitfully from BEPS recommendations could depend upon its treaty network.For example, if the information gains anticipated from Action13 (for example, a CbC reporting template) require a country to obtainthat information from the home jurisdiction of the MNE parent, thequestion of “mechanism” would arise. If the envisaged mechanismis an exchange of information provision in an existing treaty, thendeveloping jurisdictions, particularly those with more limited treatynetworks (tax treaties and TIEAs) would find it harder to obtain theinformation and proceed with their efforts to stop base erosion andprofit shifting. This issue is widely acknowledged, and is discussedmore extensively in section 3.3.5.2 below.2.3 Response to increased need for informationThe focus of the global tax community on BEPS has included recognitionof the centrality of information to tax administrations. As discussedbelow, the G20 also supports the OECD Action Plan on BEPS,including its attention to transparency, disclosure and information.The Action Plan operates against the backdrop of existing mechanismsfor the provision of information. Its value added derives fromits focus on the information-driven crisis points in BEPS. It targetsthe gaps created by the current system of providing information to tax505