The OECD published a 15-point action plan in 2013 to address base erosion and profit shifting (BEPS) in response to concerns about profits falling outside tax systems. The plan developed guidelines for determining arm's length conditions for transactions involving intangibles. The updated guidelines aim to align profit location with value-creating activities and emphasize returns associated with risk and capital. The OECD published its final BEPS package in October 2015 providing additional tools for tax administrations to challenge arrangements concerning intangibles exploitation that lack substance.