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New profiles from 12 jurisdictions provide fresh clarity on transfer pricing treatment for intangibles and baseline distribution activities.
The Organisation for Economic Co-operation and Development (OECD) has published the second batch of updated Transfer Pricing Country Profiles, offering enhanced transparency into domestic transfer pricing rules in 12 additional jurisdictions. These include Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa, and Spain.
These updated profiles integrate new insights on the treatment of hard-to-value intangibles (HTVIs) and the simplified approach for baseline marketing and distribution activities, aligning with the OECD’s ongoing Two-Pillar Solution to address tax challenges in the digital economy—specifically the work under Amount B of Pillar One.
With this release, the OECD has now covered 78 countries and jurisdictions in total. The updates are part of a rolling 2025 revision schedule, aimed at capturing developments in transfer pricing legislation and practice post-BEPS.
Key Highlights of the New Profiles
1. Hard-to-Value Intangibles (HTVIs)
The updated profiles detail how each jurisdiction addresses pricing of HTVIs—intangibles for which valuation is uncertain due to the absence of reliable comparables or because their future value is highly contingent on future events.
Jurisdictions outline their application of the OECD’s HTVI approach, which permits tax authorities to use ex post outcomes to inform ex ante pricing, subject to certain safeguards. This provides multinationals and tax practitioners critical insight into how aggressive audit positions or adjustments might arise when dealing with intangibles.
2. Simplified Baseline Distribution Rules – Amount B
The profiles also feature a new section on simplified and streamlined approaches for determining transfer pricing for baseline marketing and distribution functions. This aligns with the development of Amount B, a component of the OECD’s Pillar One solution that aims to provide predictable and standardized remuneration for routine distribution activities.
These changes are expected to ease compliance burdens for MNEs operating in multiple jurisdictions while enhancing tax certainty and administrative efficiency for tax authorities.
Scope and Methodology
Each profile covers critical components of a country’s transfer pricing framework, including:
- The application of the arm’s length principle
- Transfer pricing methods and comparability analysis
- Treatment of intangibles and intra-group services
- Cost contribution arrangements (CCAs)
- Documentation requirements
- Administrative mechanisms for dispute prevention and resolution
- Safe harbours and local implementation measures
The data in these profiles is provided directly by the jurisdictions themselves via a standardized OECD questionnaire, ensuring consistency and reliability.
Background: A Continual Expansion of Global TP Transparency
The OECD has published transfer pricing country profiles since 2009, with a major overhaul in 2017 to reflect the BEPS Project outcomes—particularly Actions 8–10 (on aligning outcomes with value creation) and Action 13 (on transfer pricing documentation and country-by-country reporting).
In 2021, the profiles expanded further to cover financial transactions and permanent establishments. The 2025 update, especially with the new HTVI and Amount B content, signals the OECD’s commitment to keeping pace with emerging business models and evolving regulatory responses in the international tax landscape.
Implications for Tax Professionals and Multinationals
For transfer pricing practitioners, CFOs, and international tax advisors, these profiles are a critical reference point to assess cross-border compliance risk and adjust internal pricing policies. As jurisdictions increasingly adopt OECD-consistent frameworks, understanding country-specific interpretations of global principles becomes essential for effective tax planning and audit defense.
The new focus areas—HTVIs and Amount B—reflect growing scrutiny on digital value chains and intangibles, where disputes often arise. This resource will help practitioners navigate transfer pricing obligations with more clarity and predictability, particularly in jurisdictions that have complex or evolving enforcement approaches.
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