Mr. Jim Clarken:

The membership issue is fundamental. Those within the OECD process are not going to design a system that is in any way impactful on or detrimental to any of its members, as we have seen in the OECD's definitions of tax havens and so on. The membership issue is a major part of the problem.

In order to engage with the OECD, developing countries would be forced to pay significant fees that they could not afford and they would not be given the technical support required for an even and fair bilateral arrangement with another country. They are not in a position to engage with those processes at the same level as every other country in the OECD. That is an immediate problem with how the initiative will be rolled out.