Tuesday, 08 March 2022

Updated Transfer Pricing Country Profiles published by OECD – Part 3

Following our previous newsflashes regarding the updated transfer pricing country profiles published by the OECD (first batch in August 2021, second batch in December 2021), the OECD has released a third batch of updated and new transfer pricing profiles for 28 countries on 28 February 2022. This brings the total number of countries covered to 91. The updates include, in line with the first and second batches, two new sections that cover 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 include up-to-date information on the countries’ legislation, such as on the arm's length principle, the transfer pricing methods, comparability analysis, intangibles, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures. The 2 new sections (financial transactions and AOA) were now added to the updated country profiles.

In this third batch, the country profiles of the following countries were updated or added:

Brazil

Korea

Canada

Liechtenstein

Chile

Lithuania

China

Luxembourg

Croatia

Malta

Dominican Republic

Panama

Estonia

Papua New Guinea (new)

Finland

Portugal

Greece

Senegal (new)

Honduras (new)

Slovenia

Hungary

Ukraine (new)

Iceland (new)

United Kingdom

Israel

Uruguay

Jamaica (new)

United States

The OECD indicated that it will continue to update existing transfer pricing profiles to include new jurisdictions and taking into account changes in legislation or practice, as they are submitted to the OECD Secretariat.

The transfer pricing country profiles can be found on the website of the OECD.


If you have questions or would like to obtain more information on this topic, do not hesitate to contact the authors:

Stefanie Van heugten – Senior Consultant at Tiberghien economics (stefanie.vanheugten@tiberghien.com)

Ben Plessers – Senior Manager at Tiberghien economics (ben.plessers@tiberghien.com)