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The OECD has released a second batch of updated transfer pricing country profiles. These profiles provide new insights into hard-to-value intangibles and simplified distribution rules in 12 jurisdictions, including Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, Netherlands, New Zealand, Singapore, South Africa, and Spain.
Key Updates in Transfer Pricing Profiles
The updated country profiles focus on key transfer pricing aspects within each jurisdiction’s domestic tax legislation, including:
- Arm’s length principle
- Methods and comparability analysis
- Intangible property
- Intra-group services
- Cost contribution agreements
- Documentation
- Dispute resolution approaches
- Safe harbours and implementation measures
This release introduces new sections on the hard-to-value intangibles approach and a simplified distribution model under the framework of Amount B—part of the OECD’s Two-Pillar Solution addressing tax challenges arising from the digital economy.
Background on OECD Transfer Pricing Country Profiles
The OECD began publishing transfer pricing country profiles in 2009, providing essential insights into both OECD and non-OECD jurisdictions. Updates to these profiles reflect the OECD/G20 Base Erosion and Profit Shifting (BEPS) actions, particularly Actions 8-10 and Action 13, which introduced significant changes to transfer pricing guidelines. The scope of these profiles has expanded over time, with the most recent updates covering financial transactions and permanent establishments.
Batch Updates and Global Coverage
With today’s release, the OECD has now updated 78 jurisdictions, with further updates scheduled throughout 2025.
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