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Diane Ringa position to negotiate many bilateral treaties. Second, to the extentthat the peer review process improves the general transparency ofdomestic banking, tax and regulatory rules of other jurisdictions,developing countries may gain. Assuming that developing countrieswould have had little leverage to instigate these transparency changeson their own, they may now find that their information requests madeto other jurisdictions are more efficiently managed.Third, a peer review of a developing country itself may providesupport for the internal efforts of the tax administration to encourageand effectuate domestic law (and practice) changes consistent withactive participation in exchange of information. This will be most truewhere the developing country receives any needed and requested technicalassistance on the more detailed facets of managing informationand requests. 71 Fourth, the current benchmark for the peer reviewsis exchange upon request (which still imposes burdens on developingcountries (see section 4.3.4.1 above)). But the domestic law and infrastructurestandards that the peer review process promotes would alsobe essential if and when countries ultimately adopt some version of automaticexchange of information. Finally, to gain the maximum benefitfrom enhanced compliance by other countries, developing countriesneed to be in a position to request information (until automatic exchangetakes hold) and to make effective use of such information. Additionalwork by the Global Forum in providing relevant assistance to developingcountries, consistent with the G20 emphasis on ensuring that all Statesbenefit from improved exchange of information, would help guaranteethat developing countries are not just providers of information but alsoknowledgeable “consumers” of exchanged information. 7271See, for example, Global Forum on Transparency and Exchange ofInformation for Tax Purposes, Tax Transparency 2013: Report on Progress,at 23 (outlining technical assistance opportunities), available at http://www.eoi-tax.org/keydocs/f6eb5861601672f34b5e25e8a4f57380#default.72See, for example, Communiqué, G20 Meeting of Finance Ministersand Central Bank Governors (Moscow, 20 July 2013), available at http://en.g20russia.ru/events_financial_track/20130719/780961553.html (“All countriesmust benefit from the new transparent environment and we call on theGlobal Forum on Exchange of Information for Tax Purposes to work with theOECD task force on tax and development, the World Bank Group and othersto help developing countries identify their need for technical assistance and564