Multinational companies operate in an increasingly regulated environment. International standards supported by OECD countries have set the tone for increased transparency, documentation, and disclosure through Country-by-Country (CbC) reporting under the Base Erosion and Profit Shifting (BEPS) project. These initiatives require companies to report information about their operations across multiple jurisdictions and consider their transfer pricing methodologies and risks. Even with the right record-keeping and support, tax audits over transfer pricing can still occur. To mitigate risks in this environment, it is advisable for taxpayers to undertake an analysis of their transfer pricing arrangements and maintain appropriate documentation. In addition, entering an advance pricing agreements, when available, can be an effective measure for reducing future transfer pricing tax risk. These efforts can require significant resources for companies that operate in multiple jurisdictions.