Transfer pricing

OECD releases seven new transfer pricing country profiles and an update of a previously-released profile


07/09/2018 - The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa and Turkey. In addition, it has also updated the information contained in Singapore’s profile. The country profiles are now available for 52 countries.


The OECD continues to publish and update the transfer pricing country profiles for OECD and all interested members of the Inclusive Framework on BEPS to reflect the current state of each country legislation and practice regarding the application of the arm’s length principle and other key transfer pricing aspects. The transfer pricing country profiles include information on transfer pricing methods, the comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures as well as to what extent the specific national rules follow the OECD Transfer Pricing Guidelines.


The information was provided by countries themselves in response to a questionnaire so as to achieve the highest degree of accuracy.


The transfer pricing country profiles reflect the revisions to the Transfer Pricing Guidelines resulting from the 2015 Reports on Actions 8-10 Aligning Transfer Pricing Outcomes with Value Creation and Action 13 Transfer Pricing Documentation and Country-by-Country Reporting of the OECD/G20 Project on Base Erosion and Profit Shifting (BEPS), in addition to changes incorporating the revised guidance on safe harbours approved in 2013 and consistency changes made to the rest of the OECD Transfer Pricing Guidelines.


Media queries should be directed to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration (+33 6 26 30 49 23) or Tomas Balco, Head of the Transfer Pricing Unit (+33 1 85 55 47 08).



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