OECD: Updated transfer pricing country profiles

Country-specific information on the treatment of hard-to-value intangibles and a streamlined approach for baseline marketing and distribution activities

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May 22, 2025

The Organisation for Economic Co-operation and Development (OECD) today published updated transfer pricing country profiles, reflecting the current legislations and practices of 11 jurisdictions, and introduced profiles for Azerbaijan and Pakistan for the first time. These profiles provide country-specific information on the treatment of hard-to-value intangibles and a streamlined approach for baseline marketing and distribution activities.

According to today’s OECD release, the profiles focus on domestic legislation concerning key aspects such as 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 latest updates include sections on hard-to-value intangibles and streamlined marketing and distribution activities, aligning with the OECD's Two-Pillar Solution addressing digital economy tax challenges.

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