The  Organisation for Economic Co-operation and Development's (OECD) updates of guidance on the Mutual Agreement Procedure (MAP) and Advanced Pricing Agreement (APA) processes provide greater tax certainty for international taxpayers and tax administrations around the world, including United States (US) multinationals working with the Internal Revenue Service (IRS).The IRS is currently updating its MAP and APA guidance, which is expected to align with the OECD guidance.The OECD released two items of guidance that will help US multinationals with the processes necessary for tax certainty in transfer pricing transactions: (1) a revised methodology for Base Erosion and Profit Shifting (BEPS) Action...