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Transparency and disclosurebe utilizing the same format and standards, thereby producing moreuniform information that may be more readily subject to comparison.Again, for a jurisdiction with limited resources, this enhanced uniformityin reporting (assuming it carries the requisite content) shouldallow the tax administration to process and evaluate the informationmore effectively — and train new tax professionals.Third, assuming that broad support for Action 13 recommendationsis ultimately achieved, and that this support is manifest insome kind of commitment across countries, then developing countriesshould benefit from the “global” obligation imposed on MNEs toprepare this information. If many countries, including countries withmore enforcement resources, are seeking the information, presumablytaxpayers will more readily comply. Moreover, this compliance wouldlikely be not only in name (for example, providing documents labelled“master file” and “template”) but also in spirit (providing materialsmeeting the expectations articulated for each of these documents).Thus, use of the BEPS process to enhance information reporting anddocument production by MNEs offers certain advantages for resourceconstrainedjurisdictions.3.3.6.2 Implementation-specific perspectiveAlthough the driving purpose behind Action 13 would be compatiblewith and would help facilitate most developing country audit andenforcement goals, the details regarding the actual implementation ofAction 13 are critical to their real-world impact. Both the final contentof the master file, the CbC template and the local file, and the mannerin which this information is provided to countries, will ultimatelydetermine whether the potential value of Action 13 is realized.3.3.6.2.1 ContentSeveral of the design questions that have arisen in the context of craftingthe master file, CbC template and local file may be particularlyrelevant for developing countries.Reporting entities: First, given that developing countries mayfind they have many permanent establishments (PEs) operating in theirjurisdiction, it will be important to clarify how that kind of presence531