BEPS Action Report 8-10, Section D.1.2.1.61 defines “risk management” as the function of assessing and responding to risk associated with commercial activity, and delineates its 3 elements as: 1) the capability to make decisions to take on, lay off, or decline a risk-bearing opportunity, 2) the capability to make decisions on whether and how to respond to the risks associated with the opportunity, and 3) the capability to mitigate risk, as well as the actual performance of all these functions.