Transfer pricing country profiles

Earlier this month, the OECD updated the TP country profiles for financial transactions and permanent establishments.


According to the OECD release, this update reflects the current TP legislation and practices of 20 jurisdictions. These updated profiles also contain new information on countries’ legislation and practices regarding the transfer pricing treatment of financial transactions and the application of the Authorised OECD Approach (AOA) to attribute profits to permanent establishments.


The transfer pricing country profiles focus on countries’ domestic legislation regarding 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 harbors, and other implementation measures.


In addition, the newly updated country profiles include two new sections:

> The first section relates to the transfer pricing treatment of financial transactions.

> The second relates to the application of the AOA to Permanent Establishments.


The purpose of this update is to reflect in a clear way the current state of the legislation of the countries listed and to indicate to what extent their rules follow the OECD TP Guidelines (listed in the What is Transfer Pricing section) and the AOA to Permanent Establishments. 


Updates to the transfer pricing country profiles will be conducted in batches throughout the second half of 2021 and the first half of 2022. With this first batch, the profiles for 20 jurisdictions have been updated, including three new country profiles from Inclusive Framework members (Angola, Romania, and Tunisia) bringing the total number of countries covered to 60.