UK and International Tax news

OECD Publishes Updated Transfer Pricing Profiles

Thursday 28th August 2025

The OECD has released a new batch of updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of 12 jurisdictions, including Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa, and Spain.

These latest 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, 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 now 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 second batch, following the first update in May, the total number of countries and jurisdictions covered now stands at 78.  The information in the profiles was provided by countries themselves in response to a transfer pricing questionnaire.

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 BEPS Project Reports, namely BEPS Actions 8-10 [Aligning Transfer Pricing Outcomes with Value Creation, and BEPS Action 13 [Transfer Pricing Documentation and CbC Reporting] which introduced revisions to the OECD TP 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.

If you would like more detail on the above, please contact Keith Rushen on 0207 486 2378.

 

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