OECD Updates Transfer Pricing Country Profiles in 2025: What Multinationals Need to Know

On By Maria Paula

In May and July 2025, the OECD released updated Transfer Pricing Country Profiles, expanding coverage to over 78 jurisdictions. These updates mark a significant step forward in transparency, offering multinational enterprises (MNEs) a clearer view of how different countries implement the OECD Transfer Pricing Guidelines.

For the first time, the profiles incorporate information on hard-to-value intangibles (HTVI) and the simplified distribution framework introduced under Amount B of the OECD’s Two-Pillar solution.

What Are the Country Profiles?

 

The OECD Transfer Pricing Country Profiles provide concise, jurisdiction-specific summaries of domestic transfer pricing legislation, practices, and administrative approaches. They serve as a practical tool for businesses, tax practitioners, and policymakers, helping to:

  • Compare country-specific TP rules with OECD standards.

  • Anticipate potential compliance challenges across jurisdictions.

  • Identify areas of convergence and divergence that may impact cross-border transactions.

1. Hard-to-Value Intangibles (HTVI)

The updated profiles now capture how jurisdictions approach hard-to-value intangibles, a long-standing area of dispute. By publishing these details, the OECD improves predictability for taxpayers, who can better understand whether (and how) ex-post outcomes may be used in local TP assessments.

 

2. Simplified Approach under Amount B

Following the February 2024 OECD report on Amount B, the 2025 profiles highlight how jurisdictions are adopting (or planning to adopt) the simplified method for baseline marketing and distribution activities. This is particularly relevant for developing countries, where simplified rules can reduce administrative burdens and promote greater certainty.

 

3. Broader Jurisdictional Coverage

With over 78 jurisdictions now profiled, the OECD has created a more comprehensive reference point for businesses operating globally. This expansion reflects growing alignment with OECD guidance, but also underscores areas where local rules diverge.

 

Why this matters for Multinationals 

The enhanced country profiles provide businesses with an invaluable compliance roadmap. Key implications include:

  • Improved planning and benchmarking: MNEs can identify where local requirements align with or diverge from OECD standards.

  • Dispute prevention: Greater transparency into HTVI treatment and Amount B adoption helps reduce uncertainty and potential audit conflicts.

  • Strategic alignment: Companies can proactively adjust policies and documentation to reflect evolving country practices.

Conclusion

The 2025 updates to the OECD Transfer Pricing Country Profiles strengthen global transparency and provide taxpayers with clearer guidance on how individual countries apply OECD principles in practice. By incorporating insights on HTVI and Amount B, the OECD is equipping both tax authorities and multinational enterprises with tools to reduce disputes, enhance compliance, and promote consistency across borders.

For MNEs, the message is clear: staying current with country profiles is no longer optional—it is a critical part of effective transfer pricing risk management