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Transparency and disclosureinformation regarding the multinational group); (b) the CbC template(which reports seven information items on a country-by-country basisfor the group, along with identifying information on entities operatingin each jurisdiction); and (c) the local file (more country-specificdetails regarding activities, assets, income and related-party transactions).The reporting package is expected to help tax administratorsassess risk and focus audit efforts. This assistance is especiallyvaluable for resource-constrained countries seeking to allocate scarceaudit resources to their more serious and relevant BEPS problems. Anumber of important issues continue to be debated regarding Action13. For example, depending upon how the information is delivered, itmay be either more or less accessible to jurisdictions. If the masterfile and CbC template are provided only to the residence jurisdictionof the MNE parent (then to be shared via exchange of informationrequests), developing countries with limited treaty networks, or limitedresources to pursue treaty requests, or both, would face a burdenin retrieving the information. At the same time, taxpayers have voicedconcerns over their own potential documentation burden, the risksof inadequate data protection and the possibility that countries coulduse the information in unintended ways (for example, as a replacementfor audit).The OECD project on BEPS is not the sole avenue for potentialreforms in transparency and disclosure. The OECD and the G20 haveadvocated for increased use of automatic exchange of information. Tofurther this goal, in 2014 the OECD released a proposed CommonReporting Standard (CRS) along with a Commentary for automaticexchange of information. In October 2014, 51 countries signed aMultilateral Competent Authority Agreement under the MultilateralConvention on Mutual Administrative Assistance in Tax Matters committingthemselves to automatic exchange. As with the work foreseenunder Action 13, reforms that increase uniform provision of informationmore directly to States can be distinctly advantageous for developingcountries trying to maximize the impact of their available tax administrationresources. A critical question is the legal framework under whichthe automatic exchange will occur. The multilateral mechanism for sharinginformation (assuming it includes countries from which informationwould likely be sought) would best serve States with limited treatypartners. Moreover, allowing developing countries temporary access to567