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Transparency and disclosure(access and use of information) and the widely differing views on whatinformation should be made available to whom, and on what terms,implementation of Action 13 will continue to generate significantdebate. The Action Plan recommendations for the delivery mechanism(that is to say, to whom the master file, CbC template and local filewill be delivered), which are expected in late 2015, will likely generatefurther discussion.3.3.5.5 Independent country actionOne important thread paralleling the entire BEPS process is thedistinct possibility that countries may pursue unilateral responsesto their BEPS problems. Such action could be in advance of broadagreement on BEPS steps or contemporaneous with it. Additionally,as noted in section 3.3.5.1 above, some countries already imposefairly extensive reporting obligations on their own multinationals,as well as on other entities doing business in their jurisdiction. Therisk or possibility of independent unilateral action by countries onBEPS problems is relevant throughout the debates on specific BEPSrecommendations. For example, in measuring and evaluating theburden imposed on taxpayers by the requirements under the masterfile, CbC template and local file, it is fair to consider the reductionin burden that corporations may experience through such a unifiedand streamlined reporting system. Similarly, taxpayers themselvesmay reassess their resistance to the OECD project on BEPS given therisk of multiple, country-specific reporting requirements that mightarise should the project not move forward with some success. Suchindividual country requirements seem all the more possible given thatcountries could use the Action 13 proposed master file and templateas a baseline in crafting their own reporting legislation. This “risk”of independent action by countries may be greatest with respect tothose jurisdictions that have some leverage in the market. In contrast,a developing country that perceives itself as having more limitednegotiating power vis-à-vis multinationals may be less inclined toimpose independent reporting requirements perceived as “unfriendly”to business. Effectively, countries could be competing based on theirrelative lack of disclosure. Those developing countries might find itadvantageous if a uniform standard of reporting is broadly adopted(along the lines of BEPS Action 13).529