1. A Solution Perspective An Open Source Collaborative and Foundational Solution Targeted at Non-OECD Member Countries February 9, 2016

2. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT FUNCTIONALTY & ADAPTATION

3. Context 3 Global Forum Roadmap Findings Common Transmission System Tender Multilateral Competent Authority Agreement BEPS Action 13 & Guidance

4. Action 13 Requires Confidentiality 4

5. IT & Staff Challenges 5 Roadmap Item #1

6. MCAA Relies Upon Questionnaire 6

7. CTS Focuses on Transmission 7

8. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT FUNCTIONALTY & ADAPTATION

9. Solution Concept 9 CTS TIE An App to TIE it all Together

10. TIE - Tax Information Exchange Application Concept is to create an Application to be used for Inter- Governmental Tax Information Exchange Like a phone handset for a telephone network – point to point ̶Specific for tax information exchange (TIE) ̶Relies upon and Enhances OECD Common Transmission System ̶Focused on CbCR information exchange, yet designed to be adapted to handle many types of information 10 Secure, Simple, Standardized

11. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT FUNCTIONALTY & ADAPTATION

12. Addressing Key CbCR Requirements Brings simplicity through a high degree of standardization and minimization of technical complexities Reduces red tape through unified governance and controls –Simple to implement, simple and secure in use –Enables developing economies to demonstrate compliance with technical aspects of MCAA/Treaty privacy requirements Future Proof – designed to be adapted to address other needs Supports effective use by end users –Integrates training on both the system and the information contained therein; definitions of CbCR data elements as disclosed 12 High Degree of Alignment with Tax Authority Needs

13. Addressing Key CbCR Requirements Provides security for data once received that matches or exceeds the data security standards referred to in the OECD implementation package and will be dynamic, addressing new security threats as these emerge –Provides confidence essential to building trust Promotes a platform upon which Tax Authorities may choose to provide transparency to taxpayers (ie: your data has been received by XXXX country type notifications) Enables consistency of understanding across jurisdictions with respect to data as disclosed and described by taxpayer 13 Benefits for Multinational Corporate Taxpayers

14. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT FUNCTIONALTY & ADAPTATION

15. Data Security Details Strong security and access control for received information Industry standard approach to information security management (ISO/IEC27000 technical standards) Data encryption at all layers of technology; storage, transmission, access Strong Tax Authority and end user registration and authentication features Validation of counterparty right to receive information prior to transmission (access control lists) User specific limitations and logging of all actions around data access, print, download, view, etc. 15

16. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT FUNCTIONALTY & ADAPTATION

17. Information Access Implications 17 Welcome to the TIE Application Receive Information ->26 New Items Send Information ->Create Exchange ->View Status of Exchanges ->Cancel Exchange Melanie Smith TrainingSupportReports Administer

18. Initial Scope – CbCR Starting Point Supports exchange of country-by-country information per OECD spec (no country extensions in first phase) Enables automatic exchange (one-to-many) & exchange upon request (one-to-one) Support Common Transmission System based messaging 18 CbCR Exchange of Information provides the high value yet reasonably limited technical scope needed for success

19. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS FUNCTIONALITY & ADAPTATION KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT

20. 20 TIE Simplifies Access to CTS Functionality Organization Registration & ID Management Outbound Transmission Management End User Registration & Access Management Inbound Transmission Management Message Storage & Encryption System & Network Event Management  TIE Relies on Common Transmission System (CTS) for Message Transmission Provides easy way to access CTS functionality Enables regional approaches Counterparty Validation Management End User Localized Training Includes the following capabilities:

21. TIE Initial Functionality CbCR Focused 21  Support Country-by-Country Report Management Basic features Manage Reportable Jurisdictions Manage Contacts of Reportable Jurisdiction Manage Reporting Multinational Corporation Accept Multinational Corporation Filing Compose CbCR Message Encrypt/Decrypt Message Send Message Manage Inbound Message Archive

22. Adaptable Long Lasting Solution Designed to be extended to address a variety of tax information exchange needs, current and future Enhancements based upon by Tax Authority needs; CRS, TP Comparables, Tax Rulings, ect. Designed so approved vendors can supply enhancements in a way that extend functionality or address country- specific needs New application modules share consistent security, look and feel and access controls, governance, etc. Support for other (regional) messaging gateways could be added over time; eg. CNN in EU 22

23. High Degree of Overlap with Other Needs 23  Common Reporting Standard (CRS) Significant features in common Manage Reportable Jurisdictions Manage Contacts of Reportable Jurisdiction Manage Reporting Financial Institution Request / Accept Reportable Account Info Compose CRS Message Encrypt/Decrypt Message Send Message Manage Inbound Message Archive Example: TIE Potential Enhanced Functionality

24. TIE Examples: Future Functionality 24 Supports Expansion from CbCR to other information exchange and functional needs Country extensions to CbCR data format Common Reporting Standards Tax Rulings Bespoke Information Exchanged upon Request Beneficial Ownership Information Tax Treaty Information Transfer Pricing Arms-length Comparables Feature: Translation of currency, language Feature: Analytics and integration with existing data

25. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS FUNCTIONALTY & ADAPTATION KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT

26. TIE Information Flow Example 26

27. SOLUTION CONCEPT INFORMATION ACCESS IMPLICATIONS ADDRESSING KEY CBCR REQUIREMENTS KEY CAPABILITIES DISCUSSION DATA SECURITY 2 EXAMPLE INFORMATION FLOW CONTEXT FUNCTIONALTY & ADAPTATION