On 9 June 2022 the OECD released new transfer pricing country profiles for Egypt, Liberia, Saudi Arabia and Sri Lanka.

The OECD transfer pricing profiles cover the OECD member countries and a number of member countries of the Inclusive Framework on base erosion and profit shifting (BEPS).

The OECD transfer pricing profiles are generally accurate because the information included in the profiles is completed by the countries themselves. The method used to compile the profiles is to issue a standard series of questions on features of the transfer pricing rules for each country. The relevant answers are then completed for each topic with references to the relevant laws and regulations, allowing some comparability between the rules of different countries.

The country profiles cover important transfer pricing issues including the arm’s length principle, transfer pricing methods, the comparability analysis, intangible property, intragroup services, cost contribution arrangements, transfer pricing documentation, simplified procedures and safe harbours.

The information includes details on the administrative approaches to preventing and resolving disputes including rulings, enhanced engagement programs, advance pricing agreements (APAs) and the mutual agreement procedure (MAP).

The profiles also include information on the law and practices relating to the transfer pricing of financial transactions, covering any specific guidance available on the issue and any other rules or regulations outside the transfer pricing rules that are relevant to the tax treatment of financial transactions.

The information includes details of the way in which the countries apply the Authorised OECD Approach to the attribution of profits to permanent establishments; or information about any other approach adopted.

The profiles assess the extent to which the rules in each jurisdiction adhere to the provisions of the OECD Transfer Pricing Guidelines. In 2017, the country profiles were significantly modified to reflect the changes resulting from the OECD/G20 BEPS reports on Actions 8 to 10 (ensuring that transfer pricing outcomes are in line with value creation) and Action 13 (three-tier documentation).

In addition to the transfer pricing country profiles, the website also includes separate information on the legislation and administrative practice of 40 countries in relation to hard-to-value intangibles (HTVIs).