On 1 December 2014, the OECD released a discussion draft (the “Discussion Draft”) on Action 8, 9 and 10 of the Base Erosion and Profit Shifting (“BEPS”) Action Plan which proposes revisions to Chapter I of the OECD Transfer Pricing Guidelines(1) and a number of special measures for public consultation. This article provides a critical overview of the proposals and analyses how these may change the application of the arm’s length principle.