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Transparency and disclosureand developed countries would likely receive little significant informationfrom this automatic exchange of information. Thus, the costof helping developing countries improve tax collection while buildingtheir internal capacity to fully participate in automatic exchangeshould not be unduly high.4.3.4.3.2 ParticipationEven with adequate infrastructure to participate in automaticexchange of information under the CRS and CAA, developing countriesmust actually be able to persuade partner countries to sign theseagreements. The bilateral version offered as the main example of aCAA would be less effective for many developing countries. It wouldhave to be negotiated on a bilateral basis with each country and couldbe completed only with current treaty partners (bilateral tax treatiesor TIEAs). The alternative, multilateral version of a CAA providedin annex 1 of the July 2104 OECD document (signed by 51 countriesin October 2014) has its legal basis in the Multilateral Convention onMutual Administrative Assistance in Tax Matters (see section 4.2.4above). 53 This multilateral version offers two key advantages to developingcountries — only a single agreement to negotiate and a wide poolof potential signatory partners. There are, however, three problems.First, with the availability and prominence of the bilateral version,there may be inadequate motivation for some countries to pursuethe multilateral one. Second, even if countries do participate in a multilateralCAA, it is not clear that they would be required to invite adeveloping country to sign. Specifically, some developing countriesthat have been unable to sign treaties with tax havens may be concernedthat tax havens would also refuse to participate in a CAA withthem. Yet these havens are key jurisdictions from which a developingcountry may need to acquire tax information, and unlike developedcountries the developing country may have little leverage to persuadeor entice the participation of the tax haven. Finally, unlike the UnitedStates FATCA regime, which inspired the CRS and CAA, it is not clearwhat sanctions would apply to non-participants. The absence of sanctionsmay be a concern for developing countries that are trying to gettax havens to join them in a CAA.53Ibid., at 215.551