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OECD Issues Guides On 31 Countries' Transfer Pricing Rules

by Ulrika Lomas,, Brussels

08 November 2017

The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of 31 participating countries.

The country profiles contain up-to-date and harmonized information on key aspects of transfer pricing legislation, provided by countries themselves, in response to a questionnaire from the OECD.

Following the outcome of the OECD/G20 Project on Base Erosion and Profit Shifting (the BEPS Project), many countries and jurisdictions have implemented measures to reflect the revisions to the Transfer Pricing Guidelines resulting from the 2015 BEPS Reports on Action 8-10 Aligning Transfer Pricing Outcomes with Value Creation and on Action 13 Transfer Pricing Documentation and Country-by-Country Reporting.

Other changes that countries have added to their regimes include the revised guidance issued on safe harbors, which was approved in 2013, and consistency changes made to the rest of the OECD Transfer Pricing Guidelines.

According to the OECD, the newly updated profiles focus on countries' domestic legislation 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 harbors, and other implementation measures.

The information contained in the TPCP is intended to clearly reflect the current state of countries' legislation and to indicate to what extent their rules follow the OECD Transfer Pricing Guidelines, the OECD said.

TAGS: Transfer Pricing | Organisation for Economic Co-operation and Development (OECD) | agreements | legislation | transfer pricing | G20 | services | Other | BEPS

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