Although generally supportive, the United States has been more sceptical of the BEPS process than many of the other participants. This stems partly from the current US political environment and partly from a perception that BEPS is focused on US multinationals. The US expects to adopt some of the reporting and documentation requirements of BEPS, including country by country reporting. Although broad changes have been proposed with respect to transfer pricing, the US has taken the position that few or no changes in its domestic law will be necessary because existing rules are generally consistent with the BEPS proposals.
