This article addresses planning opportunities and insights addressing transfer pricing  (TP) documentation, to be effected by new TP guidelines and principles established by the Organisation for Economic Co-operation and Development (OECD) as part of its Base Erosion and Profit Shifting (BEPS) action plan initiative.

The BEPS Action Plan comprises 15 actions that impact TP documentation directly or indirectly.  OECD guidance for all action plan items will be issued between September 2014 and December 2015.