OECD updates transfer pricing country profiles with new insights on hard-to-value intangibles and simplified distribution rules.

The OECD has published updated transfer pricing country profiles reflecting the current transfer pricing legislations and practices of 11 jurisdictions and issued for the first time the profiles of Azerbaijan and Pakistan. These latest country profiles present country-specific information on 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 countries' domestic legislation regarding key transfer pricing aspects, including the arm's length principle, methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, documentation, administrative approaches to avoiding and resolving disputes, safe harbour 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 will be conducted in batches throughout the first and second half of 2025. The release of this first batch brings the total number of countries and jurisdictions covered to 78.  The information in the profiles was provided by countries themselves in response to a transfer pricing questionnaire, which guarantees 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

For further information, please contact the OECD Centre for Tax Policy and Administration: ctp.communications@oecd.org.