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Diane RingModel Convention). The primary differences between the OECDModel TIEA and Article 26 include the following: (a) TIEAs can bebilateral or multilateral; (b) TIEAs focus on exchange “upon request”;(c) TIEAs cover specific taxes; and (d) TIEAs provide more detailregarding the information that the requesting State must provide toinitiate its request.For countries pursuing increased transparency and disclosurein tax, TIEAs provide a legal framework and context to agree toexchange information automatically. That is, although TIEAs call forexchange “upon request,” they permit contracting States to expandtheir cooperation through agreement by the competent authorities.Thus, just like comprehensive bilateral treaties in the case of Article 26,TIEAs can serve as the legal foundation for countries to commit toautomatic exchange. To the extent that some developing countrieshave a more limited network of comprehensive tax treaties but do havea network of TIEAs, such a role for TIEAs could become important.5.4 Multilateral Convention on Mutual AdministrativeAssistance in Tax MattersThe Multilateral Convention on Mutual Administrative Assistance inTax Matters, which originally was developed by the OECD and theCouncil of Europe in 1988, was amended in 2011 to welcome all countriesas participants. 66 At present over 60 countries have signed theConvention, including developing countries. The Convention must besigned and ratified by a country in order for it to apply — and countriescan make individual reservations to the basic terms of the Convention.As a result, reliance on the Convention depends upon whether thecountries in question have ratified it and whether they have made anyrelevant reservations to significant terms. But, as a multilateral framework,the Convention offers a potentially valuable legal foundation forcountries looking to pursue enhanced transparency and disclosureamong a group of nations in a relatively simultaneous and efficient way.66OECD-Council of Europe, Convention on Mutual AdministrativeAssistance in Tax Matters, 2011, available at http://www.oecd.org/ctp/exchange-of-tax-information/ENG-Amended-Convention.pdf.560