This paper contains an initial draft of revised guidance on transfer pricing documentation and country-bycountry reporting. It is submitted for comment by interested parties. This document does not necessarily reflect consensus views of either the Committee on Fiscal Affairs (CFA) or of Working Party n°6 (WP6) regarding the issues it addresses. Rather, it reflects limited consideration of the issues in the short time since the publication of the Action Plan and seeks to identify issues for public comment. It is considered that stakeholder comments are essential to advancing this work. Specific issues on which comments would be appreciated are noted in the draft.
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