Mr. Sorley McCaughey:

Coming from a development perspective, we welcomed the OECD BEPS process very warmly at the start and have continued to engage in it as much as we possibly can. That said, one of our main criticisms of the process is that it has not included representation or an input from developing countries – those who are suffering the most from their inability to engage in the international tax regulations and architecture. A lot of what is possibly coming out of the OECD BEPS process is very positive, in particular in terms of country by country reporting. It would be a requirement for multinational corporations to report on their activities on a country by country basis. They would have to state how many employees they had, the assets they hdld, the sales they made, taxes paid and profits made. From what we are led to believe, that is something very positive that could emerge from the process.

The other issue that is positive is automatic information exchange. Information is exchanged between jurisdictions only on a request basis, although there are instances of spontaneous information exchange. We have been advocating - it has become the agreed international desirable norm - that this information be exchanged on an automatic basis multilaterally. That is generally accepted but as of yet it is not clear how developing countries would be able to feed into this.