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OECD updates financial transactions and permanent establishments

PARIS, France – The OECD has published updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of 20 jurisdictions. These updated profiles also contain new information on countries’ legislation and practices regarding 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 focus on countries’ domestic legislation regarding key transfer pricing aspects, including the arm’s length principle, methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures. In addition, the newly updated country profiles include two new sections.

The first section relates to the transfer pricing treatment of financial transactions and the second on the application of the AOA to Permanent Establishments. The information contained in the country profiles 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 and the AOA to Permanent Establishments. The information was provided by countries themselves in response to a questionnaire so as to achieve the highest degree of accuracy.

The OECD has published transfer pricing country profiles since 2009, providing high-level information about the transfer pricing systems for OECD members and associate jurisdictions. In 2017, the country profiles were significantly modified to reflect the changes in the transfer pricing framework of jurisdictions as a result of the 2015 OECD/G20 Base Erosion and Profit Shifting (BEPS) Project reports on Actions 8-10 and on Action 13 which introduced revisions to the OECD Transfer Pricing Guidelines. The country profiles were also expanded to cover non-OECD member jurisdictions.

Updates to the transfer pricing country profiles will be conducted in batches throughout the second half of 2021 and the first half of 2022. With this first batch, the profiles for 20 jurisdictions have been updated, including three new country profiles from Inclusive Framework members (Angola, Romania and Tunisia) bringing the total number of countries covered to 60.



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