OECD: Second batch of updated transfer pricing country profiles
New insights on hard-to-value intangibles and simplified rules
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July 28, 2025
The Organisation for Economic Co-operation and Development (OECD) on July 22, 2025, published a second batch of updated transfer pricing country profiles, reflecting the current legislations and practices of 12 jurisdictions, including Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa, and Spain.
According to the OECD release:
- 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 profiles focus on the key transfer pricing aspects of each country 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 harbors and other implementation measures.
- Updates to the transfer pricing country profiles are being released in batches throughout 2025. With this second batch, following the first update in May (read TaxNewsFlash), 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, which ensures the highest degree of accuracy.