OECD: Transfer pricing “country profiles” | KPMG | GLOBAL
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OECD: Transfer pricing “country profiles” add new profiles

OECD: Transfer pricing “country profiles”

The Organisation for Economic Cooperation and Development (OECD) published new transfer pricing country profiles for 14 countries—Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay. These new profiles reflect the current transfer pricing rules and practices of each country.


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The profiles of Belgium and Russia have been updated, thus making country profiles available for 44 countries. 

The updated transfer pricing country profiles reflect revisions to the Transfer Pricing Guidelines resulting from the reports from the base erosion and profit shifting (BEPS) Actions 8-10, Aligning Transfer Pricing Outcomes with Value Creation, and Action 13, Transfer Pricing Documentation and Country-by-Country Reporting.  

The OECD release explains that the transfer pricing profiles focus on a country’s domestic law regarding key transfer pricing principles including:

  • The arm's length principle
  • Transfer pricing methods
  • Comparability analysis
  • Intangible property
  • Intra-group services
  • Cost contribution agreements
  • Transfer pricing documentation
  • Administrative approaches to avoiding and resolving disputes
  • Safe harbours
  • Other implementation measures

The information contained in a transfer pricing country profile is intended to clearly reflect the current state of each country’s law and to indicate to what extent the transfer pricing rules follow the OECD Transfer Pricing Guidelines.

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