The Internal Revenue Code (IRC or Code) requires a taxpayer to maintain transfer pricing contemporaneous documentation of its controlled transactions to avoid transfer pricing penalties. Action Plan 13 of the OECD Base Erosion and Profit Shifting (BEPS) project provided guidance on the appropriate documentation a tax authority should require from its taxpayers to provide the appropriate level of information to ascertain the arm length nature of the taxpayer’s related party transactions. Compare and contrast the U.S. documentation requirements with the OECD documentation guidance. Include the types of information required by both standards.