In this article, the author hopes to foster critical thinking by setting out the contrarian view that the OECD’s BEPS project must adapt to adequately address the needs and challenges of international tax administration in developing countries in Asia. He examines the BEPS proposals in terms of fine-tuning the “traditional architecture for international taxation”, especially with regard to the arm’s length approach to transfer pricing, and considers the difficulties of implementing OECD norms across the Asian continent, which is largely non-OECD and embraces a culturally different business environment.