On 27 January 2017, the U.S. Government Accountability Office Published a report on the potential impact on the IRS and U.S. multinationals as a result of the revised international guidance on transfer pricing developed as the OECD BEPS project. In particular the report looks at the potential impact of the revised OECD transfer pricing guidance (Actions 8-10) and Country-by-Country (CbC) reporting (Action 13). The main highlights as provided in the study are as follows: Transfer Pricing Guidance: OECD's guidance emphasizes that transfer price analysis should reflect actual economic activities, such as who controls decisions related to risk and who has...