The OECD has released a new batch of updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of 25 jurisdictions and including for the first time the profiles of Cabo Verde, Guatemala, Thailand, United Arab Emirates, and Zambia. This third batch of country profiles present new information on country-specific legislation and practice regarding the transfer pricing treatment of hard-to-value intangibles and the simplified and streamlined approach for baseline marketing and distribution activities.
The transfer pricing country profiles focus on the key transfer pricing aspects of each country’s domestic tax legislation including: the arm's length principle; methods and comparability analysis; intangible property; intra-group services; cost contribution agreements; documentation; administrative approaches to avoiding and resolving disputes; safe harbours and other implementation measures.
The country profiles released today include new sections covering the hard-to-value intangibles approach and the simplified and streamlined approach for baseline marketing and distribution activities as a result of the work on Amount B as part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy.
Updates to the transfer pricing country profiles are being released in batches throughout 2025. With this third batch, the total number of countries and jurisdictions covered stands at 83. The publication of a fourth batch in December will complete the series of updates planned for 2025. The information in the profiles are provided by countries themselves in response to a transfer pricing questionnaire, which ensures the highest degree of accuracy.
The OECD has published transfer pricing country profiles since 2009, offering high-level information on the transfer pricing systems of both OECD and non-OECD member jurisdictions. In 2017, the profiles were substantially revised to reflect the changes in jurisdictions’ transfer pricing frameworks following the 2015 OECD/G20 Base Erosion and Profit Shifting (BEPS) Project Reports – namely BEPS Actions 8-10 “Aligning Transfer Pricing Outcomes with Value Creation’’ and BEPS Action 13 “Transfer Pricing Documentation and Country-by-Country Reporting” – which introduced revisions to the OECD Transfer Pricing Guidelines. The scope of the country profiles was later expanded to include non-OECD jurisdictions and, in 2021, further extended to cover financial transactions and permanent establishments.
To access the updated list of transfer pricing country profiles, visit: https://www.oecd.org/en/topics/sub-issues/transfer-pricing/transfer-pricing-country-profiles.html.
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