As we enter the second (more challenging) phase of the BEPS project, it seems an appropriate time to reflect on some of the lessons learned to date in order to help contribute to a successful outcome. The first lesson is to ask top level questions to help scope the extent of the rules and to achieve reasonable, targeted changes. One should stay positive and suggest constructive solutions, taking every opportunity to explain our business models. Open communication will be critical to the project’s success, so it is important to engage not only with government and OECD officials, but with the broadest range of stakeholders, including NGOs.