Friday, November 10, 2017
OECD updates transfer pricing country profiles reflecting transfer pricing legislation and practices
he 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 harmonised information on key aspects of transfer pricing legislation, provided by countries themselves.
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 Reports on Action 8-10 Aligning Transfer Pricing Outcomes with Value Creation and on Action 13 Transfer Pricing Documentation and Country-by-Country Reporting, in addition to changes incorporating the revised guidance on safe harbours approved in 2013 as well as consistency changes made to the rest of the OECD Transfer Pricing Guidelines.
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 harbours 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 information was provided by countries themselves in response to a questionnaire so as to achieve the highest degree of accuracy.