OECD: Transfer pricing country profiles; updated for financial transactions and permanent establishments
Transfer pricing country profiles focus on a country’s domestic legislation regarding key transfer pricing aspects
Updated for financial transactions and permanent establishments
The Organisation for Economic Cooperation and Development (OECD) today announced the publication of updated transfer pricing country profiles of 20 jurisdictions.
According to a related OECD release, these updated profiles also contain new information on each country’s legislation and practices regarding the transfer pricing treatment of financial transactions and the application of the “Authorised OECD Approach” (AOA) to attribute profits to permanent establishments.
The transfer pricing country profiles focus on a country’s 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 harbours, and other implementation measures—as well as the transfer pricing treatment of financial transactions and the application of the AOA to permanent establishments. The information contained in the country profiles is intended to reflect the current state of the country’s legislation and to indicate to what extent the domestic transfer pricing rules follow the OECD Transfer Pricing Guidelines and the standard for the AOA to permanent establishments.
The 20 transfer pricing country profiles released or updated today are:
| Angola (new) | New Zealand (updated) |
| Argentina (updated) | Nigeria (updated) |
| Australia (update) | Norway (updated) |
| Colombia (updated) | Romania (new) |
| Costa Rica (updated) | Russian Federation (updated) |
| Czech Republic (updated) | Slovak Republic (updated) |
| Denmark (updated) | Spain (updated) |
| India (updated) | Switzerland (updated) |
| Japan (updated) | Tunisia (new) |
| Netherlands (updated) | Turkey (updated) |
Today’s release of the “first batch” of transfer pricing country profiles will be followed by more updates throughout the second half of 2021 and the first half of 2022.
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