More than 100 countries are part of the OECD’s Inclusive Framework on Base Erosion and Profit Shifting (BEPS). These jurisdictions are committed to remaking the international tax framework by implementing BEPS rules. Among the key elements of the BEPS program are changes to the permanent establishment (PE) framework to account for the taxation of digital companies, and new, stricter country-by-country reporting (CbCR) obligations related to transfer pricing practices. Unfortunately, individual jurisdictions are implementing new BEPS-related PE and CbCR rules unilaterally and to varying degrees. It’s more important than ever for multinationals to understand these trends so they know the right questions to ask to lower the risk of fines and reputational damage.