OECD: Third batch of updated transfer pricing country profiles
Total number of countries and jurisdictions covered now stands at 83.
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OCTOBER 23, 2025
The Organisation for Economic Co-operation and Development (OECD) on October 22, 2025, published a third batch of updated transfer pricing country profiles, reflecting the current legislations and practices of 25 jurisdictions, and including for the first time the profiles of Cabo Verde, Guatemala, Thailand, United Arab Emirates, and Zambia.
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 and 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 third batch, following the second update in July (read TaxNewsFlash), the total number of countries and jurisdictions covered now stands at 83. The publication of a fourth batch in December will complete the series of updates planned for 2025.
- The information in the profiles was provided by countries themselves in response to a transfer pricing questionnaire, which ensures the highest degree of accuracy.