Automatic information exchange can work
"The OECD and its member countries expect developing countries to have the skills and capacity to understand and implement the complex OECD Transfer Pricing Guidelines and the various reports that the OECD issues periodically about transfer pricing, including about intellectual property (intangibles) and cost sharing.
But if developing countries are expected to have the expertise/technical skills/capacity to understand and implement the very complex OECD Transfer Pricing Guidelines, then those same developing countries should be able to implement automatic exchange of information."
Quite so. But that is not all. He has also taken a look at the OECD Manual on the Implementation of Exchange of Information Provisions for Tax Purposes, approved by the OECD Committee on Fiscal Affairs on January 23, 2006. Spencer notes that it is:
"in effect, a guide for countries to implement automatic exchange of information. This provides to countries the information necessary (and apparently sufficient) to set up an automatic exchange of information program.
. . .
how can the UK and the OECD argue that developing countries do not at present have, and in effect will never have, the capacity to implement automatic exchange of information?"
Perhaps the OECD would like to explain.