In the wake of the October 5, 2015 release of the final package of “Base Erosion and Profit Shifting (BEPS)” reports from the OECD, as well as the European Commission’s decision on October 21 accusing Fiat and Starbucks of violating EU state aid rules, multinational corporations are looking at their intangible property ownership globally and assessing what, if any, changes need to be made to their global transfer pricing structures.