In 2013, the Organisation for Economic Co-operation and Development (OECD) and the G20 Countries developed a 15-Point Action Plan in an effort to address Base Erosion and Profit Shifting (BEPS). The OECD and G20 Countries worked together on this Action Plan in an attempt to address concerns about aggressive tax planning by multi-national enterprises (MNE) to reduce their tax liabilities by shifting profits to low or no tax jurisdictions. Part of the Action Plan called for changing transfer pricing documentation to enhance transparency, certainty, and predictability for tax administrators and taxpayers. The United Kingdom and Australia are two examples of countries that have quickly adopted the transfer pricing documentation guidance. MNEs need to reevaluate their transfer pricing documentation to ensure that it meets the standards set forth by the Action Plan, while considering the nuances of the rules in the various countries in which they do business.