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Transparency and disclosureConvention on Mutual Administrative Assistance in Tax Matterswould obviate the need to enter into many bilateral arrangements. Thiswould be an advantage for countries with few current treaties and limitedresources for tax administration. In October 2014, over 50 countriessigned a multilateral CAA to implement automatic exchange ofinformation (see section 4.2.4 above). However, even this path (use ofthe Multilateral Convention) would not guarantee that crucial jurisdictionswould join a developing country in exchange of information.Another barrier for developing countries is the “reciprocal” natureof the CAA. Exchanges would start only after both countries compliedfully under the agreement. Phasing in reciprocity would allowdeveloping countries to receive valuable tax information and tacklebase erosion straight away, while building their internal capacity tocomply with all aspects of the CAA. Other potentially interestinginitiatives for transparency and disclosure include: (a) efforts such asthe Extractive Industries Transparency Initiative, which encouragesindustry-based reporting of tax payments (with both business andgovernment reporting payments and receipts); and (b) bilateral andregional efforts to replicate the kind of information exchange beingpromised under IGAs that have been signed in the wake of the newUnited States reporting requirements for financial entities.5. Existing mechanisms supporting transparency anddisclosure5.1 OverviewSignificant attention has been directed to transparency and disclosurein recent years, but these concepts are not new to the tax system. Forexample, tax treaties have included exchange of information provisionsfor decades, which although more limited in scope and effectthan some of the transparency and disclosure projects currently underway, have nonetheless sought to enhance access of a tax administrationto vital taxpayer data. A brief review of these existing mechanismswhich support and facilitate tax transparency and disclosure provides:(a) a better understanding of what may be needed in new mechanisms;and (b) the role that these current agreements or structures can playin supporting any new developments in transparency and disclosure.555

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