handbook-tb

Transparency and disclosurethe MNE parent jurisdiction (assuming that language is not English).However, the personnel constraints that developing country taxadministrations face include the limited pool of English-speaking taxprofessionals with sufficient international tax training to effectivelyreview the files, make risk assessments and then pursue taxpayeraudits where appropriate. If more information is made available in thelanguage of the developing country, the number of tax professionalsin government available to work on audits, reviews and examinationsmay increase.Burden: Fifth, the dominant taxpayer critique of Action 13reporting (master file, CbC template and local file) has been that of theburden it imposes on taxpayers (see section 3.3.5.1 above). Althoughthe question of burden is important, and requested information shouldbe useful and reasonable in context, the balance of benefit and burdenmay look different from a developing country perspective. Taxpayershave urged that they not be asked to provide difficult-to-gather datathat a country would be unable to use. This objection is not levelledsolely at developing countries, but it is one that is heightened wherea country has limited resources and is ultimately constrained in itsability to process information meaningfully. However, despite thisclaim, which might suggest that the benefits to developing countrieswould be less than the burden to the taxpayer, a broader look at thebenefits and burden question might produce a different conclusion.Developing countries are often understood to be highly dependentupon income taxes, specifically corporate income taxes, for their revenuebase. There are a number of factors contributing to this fiscalpicture and although it may shift in the long term, at present thereis a serious cost to the fiscal welfare and stability of these countrieswhen they are unable to collect corporate income tax otherwise due.Additionally, developing countries have fewer internal resources toengage in extensive monitoring and reviewing of multinational taxpayersand their tax planning. Thus, the benefit to these jurisdictionsin having MNEs provide relatively uniform, comprehensive informationof both a qualitative and quantitative nature that assists in riskassessment and in audit is distinctly valuable. That said, the BEPSproject is a group effort by countries to respond to BEPS. However, inmaking a group-wide assessment of the burden imposed on taxpayersby Action 13 compared to the benefit for tax administrations, it will533