The OECD has updated transfer pricing country profiles for eight jurisdictions, detailing domestic rules on key principles such as the arm’s length standard, documentation requirements, and dispute prevention measures, and assessing alignment with the OECD Transfer Pricing Guidelines.
The OECD has published the revised transfer pricing country profiles, including profiles for Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Greece, Iceland, Korea (Rep.), and Norway on 22 January 2026.
These profiles focus on countries’ domestic legislation regarding key transfer pricing principles, including the arm’s length principle, transfer pricing methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures.
The information contained in these profiles is intended to clearly reflect the current state of countries’ legislation and to indicate the extent to which their rules follow the OECD Transfer Pricing Guidelines.
In a global economy where multinational enterprises (MNEs) play a prominent role, governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation.
The OECD Transfer Pricing Guidelines are a cornerstone of the international tax system, providing a stable and efficient business environment for MNEs while ensuring a principled allocation of profits across jurisdictions. The Guidelines provide a framework for applying the arm’s length principle, which constitutes the international consensus on pricing cross-border transactions between associated enterprises.
On 19 February 2024, the Guidelines were updated to incorporate the guidance on Amount B of Pillar One, in line with the July 2023 Outcome Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. This guidance provides a simplified and streamlined approach to the application of the arm’s length principle to baseline marketing and distribution activities, which is particularly helpful for low-capacity jurisdictions.
