A/HRC/31/61 for the Reform of International Corporate Taxation. To promote accountability, his recommendations are addressed to specific stakeholders. Recommendations to Member States 78. States should ensure that human rights are respected and advanced in all measures and activities undertaken to curb illicit financial flows. 79. States should actively participate in the global movement towards automatic exchange of tax information, in order to prevent hiding of offshore assets and income streams. Out of consideration for the unique challenges faced by developing countries, and in the spirit of the principle of common but differentiated responsibilities, there should be a fixed transition period during which lower-income countries receive tax information automatically without a requirement for full reciprocity. This will allow time for their domestic systems to be modified and improved, so that they are able to take full advantage of the benefits of information exchange. 80. States should impose a legal requirement for the public disclosure of beneficial ownership information, in order to eliminate the potential for anonymous ownership of companies, trusts and foundations. 81. States should require transnational businesses to report publicly on a countryby-country basis, in order to expose major misalignments between the distribution of profit and the location of real economic activity. These reports should be made freely available to tax administrations and should be made available to the public within a certain period of filing. 82. States must hold financial institutions to account for their role in facilitating tax evasion. Robust regimes should be put in place for the supervision of financial institutions by financial supervision agencies. Such regimes should require mandatory reporting of transactions that may involve illicit activity. States should ensure that financial and service providers comply with strict due diligence procedures, as laid out, for example, in the Financial Action Task Force recommendations. 83. States should conduct human rights impact assessments of their tax policies, to ensure that they do not have negative impacts abroad. These should be periodic and independently verified, with public participation in defining the risks and potential extraterritorial impacts. Impact assessments should analyse not only the implications for revenue streams, but also the distributive and governance spillover effects of a country’s tax regime abroad. If and when negative spillovers are found, impact assessments should trigger policy action including explicit recommendations for responsible parties and clear deadlines for remedies and redress. 84. States should ensure that human rights impacts caused by corporate tax abuse should form part of due diligence required by business actors and addressed in national action plans on business and human rights. 85. States should uphold their commitments in the Addis Ababa Action Agenda and target 17.1 of the Sustainable Development Goals with respect to capacitybuilding for tax administrations, including through targeted use of ODA. Technical assistance and other forms of support should also be provided, including through South-South cooperation or participation in the Addis Tax Initiative, launched at the third International Conference on Financing for Development. 86. Capacity-building initiatives in other key areas for fighting tax abuse should receive similar support. To curb trade misinvoicing, developed countries should contribute toward the development of a global trade-pricing database that would give customs officials access to global average price of products. Financial and other forms 20

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