Under BEPS Action Plan 13, BEPS report recommends that countries adopt a standardized approach to transfer pricing documentation, wherein it…

(a) Advantages of the three-tier structure mandated by BEPS Action Plan 13: (a) Taxpayers will be required to articulate consistent transfer pricing positions; (b) Tax administrations would get useful information to assess transfer pricing risks; (c) Tax administrations would be able to make determinations about where their resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries;