On 15 June 2016, the OECD announced that the BEPS amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations have been approved by the OECD Council. The amendments include those developed as part of BEPS Project Actions 8-10 (Aligning Transfer Pricing Outcomes with Value Creation) and Action 13 (Transfer Pricing Documentation and Country-by-Country Repor…