The OECD recently updated the “Transfer Pricing Country Profiles,” providing detailed guidance on how individual countries implement their domestic tax legislation related to transfer pricing. These profiles cover key areas, including the “arm’s length principle”, comparability analysis, intangible property, intra-group services, methods for preventing and resolving disputes, safe harbors, and other implementation measures.
Following an initial set of updates released in May 2025, the OECD has just issued a second batch of updated transfer pricing country profiles, incorporating the latest versions for all country profiles. This recent release reflects the current transfer pricing legislation and practices of 12 specific jurisdictions: Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa, and Spain.
These newest country profiles also introduce fresh insights on how to handle “hard-to-value intangibles” (complex intellectual property) and include references to the Simplified and Streamlined Approach for Baseline Marketing and Distribution Activities. Critically, these profiles also provide specific insight into whether each country’s domestic transfer pricing framework currently allows the application of this Simplified and Streamlined Approach, which directly points to the applicability of the Amount B component of Pillar 1 despite recent setbacks for Pillar 2.
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Source: https://www.oecd.org/en/topics/sub-issues/transfer-pricing/transfer-pricing-country-profiles.html