Updated TP Country Profiles – OECD

The OECD has today published the updated Transfer Pricing country profiles of 11 jurisdictions namely Colombia, Croatia, Denmark, Honduras, Indonesia, Jamaica, Luxembourg, Malaysia, Saudi Arabia, Turkey and Slovak Republic. Further the Transfer Pricing profiles of Azerbaijan and Pakistan have been included for the first time.

The country profiles focus on the country’s current TP Regulations encompassing arm’s length principle, TP 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.

In addition to the above, the first batch of the updated country profile released today, includes new sections on transfer pricing treatment of hard-to-value intangibles and simplified and streamlined approach for baseline marketing and distribution activities as a result of the work on Amount B -Pillar Two Solution addressing tax challenges arising from Digitalisation of the Economy.

The updates are expected to be conducted in batches throughout the first and the second half of 2025. The release of this batch by OECD, brings the total number of countries and jurisdictions covered to 78.

The OECD updated list of country profiles can be accessed through the below link
https://www.oecd.org/en/topics/sub-issues/transfer-pricing/transfer-pricing-country-profiles.html