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Without a stable and adequate tax base, countries lose the financial capacity to provide the infrastructure, social services and development opportunities important to their citizens. In response, the G20 and the Organisation for Economic Co-operation and Development (OECD) organized the project on Base Erosion and Profit Shifting (BEPS). Much of the project has been focused on substantive law — the rules and practices that can allow the tax base of a country to be eroded and profits to be shifted out of the country. But the project recognizes that improved substantive tax rules alone are not sufficient to guarantee the tax base of a country. Without adequate transparency and disclosure of tax information to the taxing authorities, even the most carefully designed substantive tax rules will fail to protect the base. This chapter explores both the existing mechanisms for transparency and disclosure, and the new developments including country-by-country reporting, automatic exchange of information, beneficial ownership registries, and government exchanges. The primary focus of the analysis is understanding how these various regimes may impact developing countries.


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6 Sep 2022
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  • Subject
    • International Law

    • International Trade Law

    • Taxation

    • Taxation-International

  • Journal title
    • United Nations Handbook on Selected Issues in Protecting the Tax Base of Developing Countries, Second Edition

  • Pagination
    • 571-652

  • Date submitted

    6 September 2022