As stated above, HMRC has not yet faced the situation where an overseas-based business refuses to pay the correct amount of tax as assessed by HMRC. HMRC told us that it has bilateral and multilateral agreements with other countries that would allow it to ask the tax authority in the relevant country to assist in the collection of a tax debt. HMRC acknowledges that whether such cooperation would be forthcoming is debatable, given that the tax is a controversial one in some countries.57 Ensuring compliance with the OECD reforms