criminal activity and corruption.<sup>67</sup> Tax administrations can also benefit from the exchange of information about the types of structures and entities that are being exploited for the purposes of offshore tax evasion. This type of intelligence sharing is something that tax administrations that are members of the OECD’s Forum on Tax Administration (FTA) have undertaken and the FTA’s current work program includes a project on “Tackling offshore evasion: intelligent use and assurance of CRS data”.<sup>68</sup> Regional groupings of tax administrations, such as the African Tax Administration Forum, the Inter-American Center of Tax Administrations and the Intra-European Organisation of Tax Administrations, also help to encourage the sharing of intelligence between their members, which include many developing economies.

In addition to the data that are being exchanged under the Common Reporting Standard, countries are beginning to develop registers of beneficial ownership. The UK government plans to launch a public beneficial ownership register in 2021. EU member states will make public the ownership of legal entities such as companies by January 2020 and other countries around the world have also committed to put in place public registers of ownership.<sup>69</sup> Increased transparency about ownership will clearly help tax administrations across the world to detect and deter offshore tax evasion.

Addressing profit diversion by MNEs is more complex as it requires information about entities and transactions that may not be directly subject to a tax administration’s jurisdiction. However, the G20/OECD BEPS project’s Action 13 outcomes are improving the data available to tax administrations about the global operations of MNEs with a presence in their jurisdictions. The Master File in standard transfer pricing documentation includes information about the overall structure of the group, including the geographical location of operating entities. It also includes information about the MNE’s intangibles and financing. Whenever available, the Country by Country report is likely the best source of information on risks of profit diversion that need closer examination. Currently, the number of MNEs preparing Country by Country reports is limited, partly because preparing these reports represents a significant compliance burden for taxpayers. The current Country by Country reporting standard is subject to review in 2020 and its value to developing economies should be an important element of that review. It is possible that a simpler reporting requirement that focuses more on profits subject to a low rate of taxation could be both less onerous to prepare and more valuable for developing economies.

The review of the Country by Country reporting standard will take place against the backdrop of a trend towards greater transparency of reporting by MNEs. The Extractive Industries Transparency Initiative has developed a standard that requires the disclosure of information about the governance of natural resources. This includes information about the beneficial ownership of entities involved in the extractives sector and comprehensive disclosure of information about taxes paid by companies and government revenues.<sup>70</sup> The European Union has already mandated public country by country reporting by listed and large unlisted companies in the extractive and logging industries. In 2016 the European Commission

> 67 Project Wickenby in Australia illustrates what can be achieved by a coordinated cross-agency approach to the problem of offshore tax evasion. For more information visit the ATO website: https://www.ato.gov.au/General/The-fight-against-tax-crime/News-and-results/Project-Wickenby-hasdelivered/.

> 68 For more information about the FTA and its current projects visit: http://www.oecd.org/tax/forum-on-taxadministration/about/.

> 69 For a recent review of registers of beneficial ownership see:

> https://researchbriefings.parliament.uk/ResearchBriefing/Summary/CBP-8259#fullreport.

> 70 https://eiti.org/sites/default/files/documents/the_eiti_standard_2016_-_english.pdf.

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