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Transparency and disclosurethe size and nature of the local economy, and the size and nature ofthe MNE and its activities both globally and locally); (d) expectationsregarding document retention and updates; (e) language requirementsfor reporting; (f) nature and impact of documentation penalties; (g)confidentiality; and (h) actual implementation (domestic law changes,oversight of taxpayer reporting, mechanism(s) for delivering information— centralized to MNE parent, locally or other options). Amongsome of the most important concerns that have emerged regarding thedesign and implementation challenges are: (a) burden: the gap betweenhow MNEs manage their group reporting and the expectations underAction 13; (b) delivery mechanism: the need to ensure taxpayer confidentialitywhile also ensuring meaningful access to reported information,especially by developing countries; (c) use of information: theexpectation that the CbC template will not lead countries to bypassaudit and directly impose a transfer pricing adjustment, and theexpectation that countries will not abandon an arm’s length approach.Developing countries may want to devote particular attentionto the following key issues in Action 13: (a) the broad goal of Action13 (to improve information necessary for tax authorities to make validrisk assessments) may be especially valuable to resource-constraineddeveloping countries which must decide where and how to allocatescarce audit resources; (b) similarly, if the Action 13 reporting package(master file, CbC template and local file) becomes the MNE standard,the increased reporting uniformity should also help developingcountries conserve and best direct their tax and audit resources; (c) thechoice of reporting language can also directly impact the ability ofdeveloping countries to access information; thus, reporting at least thelocal file in the local language may be very important; (d) if MNEsprovide the information directly to the home jurisdiction of the parentwith the expectation that other countries then request some or all ofthe information, the actual availability of the data will be diminishedfor developing countries that have a smaller treaty network and/orlimited tax enforcement staff to make the treaty-based inquiries forall information sought; (e) the ability to ensure confidentiality underdomestic law will be vital regardless of the precise delivery mechanism;and (f) the capacity-building support that would benefit the developingcountry in making the most of information available under theAction 13 reporting package.539