OFCs (e.g. the modern corporate tax havens)(Conduits are: Netherlands, United Kingdom, Switzerland, Singapore, and Ireland) Sink OFCs rely on Conduit OFCs to reroute funds from high-tax locations using the BEPS tools which are encoded, and accepted, in the Conduit OFC's extensive networks of bilateral tax treaties. Because Sink OFCs are more closely associated with traditional tax havens, they tend to have more limited treaty networks. CORPNET's lists of top five Conduit OFCs, and top five Sink OFCs, matched 9 of the top 10 havens in the Hines 2010 tax haven list, only differing in the United Kingdom, which only transformed their tax code in 2009–12, from a "worldwide" corporate tax system, to a "territorial" corporate tax system. All of CORPNET's Conduit OFCs, and eight of CORPNET's top 10 Sink OFCs, appeared in the of 22 OFCs. However, this theoretical work has been brought into question. Many of the "sink" jurisdictions by CORPNET's standards have proved to be conduit jurisdictions. When Economic Substance legislation was brought in, practically all of the companies in places like the Cayman Islands and British Virgin Islands were out of scope because BEPS is not a relevant industry in those jurisdictions. Those jurisdictions concentrate more on investment funds, which are self-evidently conduit vehicles where investors are not taxed in the OFC but in full where they are tax resident. Lists FSF–IMF 2000 list The following 46 OFCs are from the June 2007 IMF background paper that used a qualitative approach to identify OFCs; and which also incorporated the April 2000 FSF list which had also used a qualitative approach to identify 42 OFCs. (*) Groups are as per the IMF June 2000 categories: (‡) Dominica, Grenada, Montserrat and Palau were not on the FSF April 2000 list of 42 OFCs but were on the IMF June 2000 list of 46 OFCs. IMF 2007 list The following 22 OFCs are from an April 2007 IMF working paper that used a strictly quantitative approach to identifying OFCs (only where specific data was available). (†) In on both the April 2000 FSF list of 42 OFCs, and the June 2000 IMF list of 46 OFCs. (Top 5 Conduit OFC) The IMF list contains all 5 largest Conduit OFCs: Netherlands, United Kingdom, Switzerland, Singapore and Ireland (Top 10 Sink OFC) The IMF list contains 8 of the 10 largest Sink OFCs: missing British Virgin Islands (data was not available), and