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Transparency and disclosureimproved knowledge and understanding, their focus and “solutions”are different. Actions 12 and 13 target specific taxpayer conductthrough enhanced reporting requirements for actual taxpayers. BothActions 12 and 13 anticipate changing the kinds of information thattaxpayers must provide to countries. The new information presumablywould enable a country to evaluate a multinational taxpayer moreeffectively and accurately and identify conduct that is creating BEPS(either by aggressive planning or by cross-border related-party transactionsand structures). In that way, Actions 12 and 13 function moreas a support to and enhancement of the audit function.3.2.1 Goals of Action 11In contrast to Actions 12 and 13, Action 11 targets a more systemicgoal — obtaining a comprehensive, overall picture of the BEPS problem.Action 11 is expected to “[d]evelop recommendations regardingindicators of the scale and economic impact of BEPS and ensure thattools are available to monitor and evaluate the effectiveness and economicimpact of the actions taken to address BEPS on an ongoing basis.”For example, Action 11 would seek to calculate the resulting effects onoverall tax receipts, total employment, geographic location of employment,investment in physical capital, investments in knowledge-basedcapital, tax competition, and so forth. 13 Once data and methodologiesare in place to “measure” the problem, it is expected that indicatorsand tools to monitor the success of BEPS actions taken by countrieswill be developed under Action 11. 14The focus is on not only what is happening within a givencountry owing to BEPS, but also the “spillover” effects on otherjurisdictions. 15 This newly collected information is expected to help13OECD, Request for Input, BEPS Action 11: Establish methodologies to collectand analyse data on BEPS and the actions to address it (4 August 2014), at 3, availableat http://www.oecd.org/ctp/public-request-for-input-beps- action-11.pdf.14Ibid.15See, for example, International Monetary Fund, “Spillovers in InternationalCorporate Taxation,” (2014) IMF Policy Paper, at 1, available at http://www.imf.org/external/np/pp/eng/2014/050914.pdf. It observes that “spillovers[from the international aspects of corporate taxation] are especiallymarked and important for developing countries.”509

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