On 13 December 2021 the OECD released updated transfer pricing country profiles for 18 countries, together with new transfer pricing profiles for Albania, Kenya and the Maldives. The OECD has now created transfer pricing profiles for a total of 63 countries, including OECD member countries and some non-member countries.
The 18 updated transfer pricing profiles relate to Austria, Belgium, Bulgaria, France, Georgia, Germany, Indonesia, Ireland, Italy, Latvia, Malaysia, Mexico, Peru, Poland, Seychelles, Singapore, South Africa and Sweden.
The OECD country profiles look at the most 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 transfer pricing dispute resolution. The profiles also include information on the law and practices relating to the transfer pricing of financial transactions and details of the way in which the countries apply the Authorised OECD Approach to the attribution of profits to permanent establishments.
The profiles examine to what extent the rules in each jurisdiction adhere to the provisions of the OECD Transfer Pricing Guidelines. The countries themselves provide the information to the OECD so the profiles are able to achieve a high level of accuracy. In 2017, the country profiles were significantly modified to reflect the changes resulting from the OECD/G20 Base Erosion and Profit Shifting (BEPS) reports on Actions 8 to 10 (ensuring that transfer pricing outcomes are in line with value creation) and Action 13 (three-tier documentation).
Updates to the transfer pricing country profiles will continue to be released during the first half of 2022.
