On 3 August 2021 the OECD issued an updated version of some of its transfer pricing country profiles, These include new country profiles for Angola, Romania and Tunisia, and updated profiles for seventeen other countries. The updated profiles have been expanded to include information on the law and practices relating to the transfer pricing of financial transactions and the way in which the countries apply the Authorised OECD Approach to the attribution of profits to permanent establishments.
The OECD country profiles look at the important transfer pricing issues including the arm’s length principle, transfer pricing methods, the comparability analysis, intangible property, intragroup services, cost contribution arrangements, documentation and dispute resolution. The profiles look at the extent to which the rules in each country follow the provisions of the OECD Transfer Pricing Guidelines. The countries themselves provide the information to the OECD so a high level of accuracy is achieved.
The OECD intends to issue updates to the transfer pricing country profiles in batches during the second half of 2021 and in the first half of 2022. Currently 60 jurisdictions, including OECD member countries and some non-members, are covered by the country profiles.