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Transparency and disclosuredisclosures. But the Discussion Draft anticipates the need for bothdocumentation and mispricing penalties in some cases. As countriesexamine their own documentation and substantive pricing penalties,it is important to bear in mind the risk that taxpayers will “favour”jurisdictions with more severe penalties: taxpayers might devotemore resources to documentation compliance in such jurisdictionsand, where in doubt on pricing, shift profits to the jurisdiction withhigher penalties (to avoid the imposition of such penalties). Given thatdeveloped countries frequently have well-established transfer pricingdocumentation and substantive penalties regimes, developing countriesshould carefully evaluate their own penalty regimes with theseobservations in mind.3.3.6.3 OptionsAssuming that developing countries secure workable access to themaster file and the CbC template under the final delivery mechanism,there remains the question of how they can best use this information.Given the resource constraints faced by many developing countries,targeted capacity-building might enhance the ability of these countriesto use the information received from all three formats (masterfile, CbC template and local file) in a strategic manner. For example,training for developing country tax auditors could focus on theinformation included in these files and how to use that informationto make overall risk assessments and, where appropriate, to pursuetaxpayer-level audits. Using “case studies” of hypothetical taxpayerswith corresponding master files, CbC templates and local files wouldhelp developing countries not only receive the information but beginto use it effectively and more immediately to tackle base erosion andprofit shifting. 33 Real-time technical assistance and capacity-buildingcould also be pursued through the “Tax Inspectors Without Borders”programme 34 currently being piloted by the OECD, which provides33See, for example, African Tax Administration Forum, A PracticalGuide on Information Exchange for Developing Countries (2013), at 46-47(outlining an abbreviated version of the case study concept in the context ofrequesting information).34See, generally, OECD website at http://www.oecd.org/tax/taxinspectors.htm.537