TPG2022 Annex to OECD Transfer Pricing Guidelines paragraph 14

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The outcomes envisaged by the Working Party from the identification and analysis of difficult case paradigms could include the development of examples illustrating the application of the Guidelines in cases (identified for discussion) where the principles already contained within the Guidelines can be applied. It could also include identification of areas where the Guidelines could be amended to provide clearer guidance or where new material could be inserted into the Guidelines.

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