"Smaller" Multinational Enterprises & Transfer Pricing

How saving $20K nearly cost this taxpayer $2.7 million!

It seems that every day now there is an article of some sort addressing aggressive tax structures, often utilizing offshore entities, and the ramifications of (implied) inappropriate, underlying transfer pricing policies. Recently, this has clearly been due to the news of the "Panama Papers" disclosure or, more generally over the past couple of years, the result of the recently finalized Base Erosion and Profit Shifting Project reforms published by the Organization for Economic Corporation and Development.

These articles have tended to focus on very large multinational enterprises (obviously, talking about hundreds of millions of tax dollars tends to be more newsworthy and eye-catching). This targeted focus has, perhaps, given many "smaller" multinational enterprises (and, in instances, their professional advisors) the false impression that they do not have to worry much about their cross-border-related party