OECD Releases More Transfer Pricing Country Guides

by Ulrika Lomas, Tax-News.com, Brussels

12 April 2018

The OECD has published new transfer pricing country profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay, bringing the number of such overviews published by the OECD to 44.

The profiles explain the current transfer pricing legislation and practices of each country. Profiles for Belgium and Russia have also been updated.

The profiles are intended to support taxpayers to understand how countries have revised their transfer pricing policies in line with the OECD's revisions to its Transfer Pricing Guidelines (TPGs).

The information contained in the transfer pricing country profile 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 TPGs were amended to incorporate the work of the OECD on base erosion and profit shifting Actions 8-10, on aligning transfer pricing outcomes with value creation. The TPGs were also amended to add provisions concerning the BEPS minimum standard on transfer pricing documentation and country-by-country reporting and the revised guidance approved in 2013 on safe harbors.

The transfer pricing 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.

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