Confidentiality limits on country-by-country reports restrict use to high-level risk assessment and analysis, not transaction-level adjustments.

Confidentiality and Convention safeguards restrict disclosure and use of exchanged CbC Reports; use is limited to high-level assessment of transfer pricing, base erosion and profit shifting risks and for economic or statistical analysis, and CbC data alone does not suffice for transfer pricing adjustments. Competent Authorities must notify the Co-ordinating Body Secretariat, insofar as permitted by law, of any non-compliance and remedial actions, and the Secretariat will notify other Competent Authorities with which the notifying authority has an effective exchange relationship.

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