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Transparency and disclosuremaster file, CbC template and local file is fairly uniform and consistentover time, across countries and across taxpayers, the information maybe easier for tax authorities to use. For resource-constrained developingcountries, this uniformity could facilitate training and decreaseaudit burdens.5.2.5 Article 26 of the Model Conventions: summaryExisting bilateral tax treaties still constitute a relevant tool in encouragingtransparency and disclosure. First, they can provide the legalbasis or framework for an agreement between competent authoritiesto exchange information on an automatic basis (as can TIEAs or theMultilateral Convention on Mutual Administrative Assistance in TaxMatters (see sections 5.3 and 5.4 below)). Second, they may explicitlypermit requests regarding persons neither resident nor engaged ineconomic activity in the State from which information is sought. Anautomatic exchange of information arrangement would be unlikelyto include data regarding such persons. Third, the “residual” abilityunder Article 26 provisions to seek information upon request remainsuseful if a country finds that it requires information beyond the scopeof that provided automatically.Although bilateral treaty provisions based on Article 26 ofeither the United Nations or the OECD Model Convention areinadequate in meeting the full range of transparency and disclosureneeds of tax administrations today, they continue to provide possibleaccess to information not likely available through automatic exchangeof information or through the taxpayer reporting envisaged by BEPSAction 13 recommendations.5.3 Tax Information Exchange AgreementsTIEAs are stand-alone agreements, typically negotiated betweencountries that have not negotiated a bilateral tax treaty, that focusexclusively on exchange of information. The expectation is that evencountries that do not have a bilateral treaty may still seek to exchangetax information. The TIEA provides the legal basis and structure fordoing so. The OECD Model TIEA, not surprisingly, is very similar toArticle 26 of the OECD Model Convention (and the United Nations559