The OECD has published updated transfer pricing profiles for 20 different countries, reflecting the current state of the countries’ transfer pricing legislation and practices.
The updated profiles also include two new sections which contain information on treatment of financial transactions and indicate to what extent their rules follow the OECD Transfer Pricing Guidelines the application of the Authorised OECD Approach (AOA) to attribute profits to Permanent Establishments.
The transfer pricing country profiles focus on domestic legislation of each country with regard to 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. The information was provided by countries themselves in response to a questionnaire.
The OECD has published transfer pricing country profiles since 2009, providing high-level information about the transfer pricing systems for OECD members and associate jurisdictions. In 2017, the profiles were significantly modified to reflect the changes in each jurisdiction’s transfer pricing framework as a result of revisions to the OECD Transfer Pricing Guidelines arising from the 2015 OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. The list of country profiles was also expanded at this time to cover non-OECD member jurisdictions.
Updates to the complete list of OECD transfer pricing country profiles (60 countries in total) will be conducted in batches throughout the second half of 2021 and the first half of 2022. This first batch covers the profiles for 20 jurisdictions, including three new country profiles from Inclusive Framework members (Angola, Romania and Tunisia).
Countries updated in this first batch release: Angola, Argentina, Australia, Colombia, Costa Rica, Czech Republic, Denmark, India, Japan, Netherlands, New Zealand, Nigeria, Norway, Romania, Russian Federation, Slovak Republic, Spain, Switzerland, Tunisia, and Turkey.
The updated transfer pricing country profiles can be found at: https://oe.cd/transfer-pricing-country-profiles.
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