Rocco Femia was quoted regarding the OECD's recent base erosion and profit-shifting plan (BEPS) deliverables and their potential impact on multinational companies. Much of the substance of the transfer pricing guidance to date is contingent upon the OECD's resolution of other related BEPS matters such as risk allocation in transfer pricing arrangements and recharacterization issues in transactions. "I think multinationals are unlikely to substantially change their operations until those issues are addressed and resolved," Femia said. "All multinationals know their structures need to be revisited and may need some changes, and for many years, large multinationals have been moving toward arrangements that marry intangible ownership and risk with significant substance. But in terms of implementing very large changes, it's a bit of a waiting game."