The Organization for Economic Cooperation and Development (OECD) announced the update of its Transfer Pricing Country Profiles, incorporating new jurisdictions and strengthening the global reach of this tax transparency tool. With the third batch published in October 2025, the total number of countries and jurisdictions covered now stands at 83, and a fourth batch is planned to complete the updates scheduled for 2025.
What are the OECD’s Transfer Pricing Country Profiles?
The OECD’s Country Profiles are national fact sheets that summarize the legislation, administrative practices, and interpretative approaches that each country applies to its transfer pricing regime. These fact sheets bring together essential information on:
- Application of the arm’s length principle.
- Methods recognized by local regulations.
- Treatment of intangibles and intra-group services.
- Documentation requirements (local report, master report, country-by-country report).
- Dispute resolution procedures and administrative approaches (including safe harbors and APAs).
Since their creation in 2009, the profiles have established themselves as a reference source for tax administrations, multinational companies, and advisors, allowing for a standardized comparison of the regulatory framework of each jurisdiction.
What did the 2025 updates contribute?
In 2025, the OECD published the updates in several batches:
- May 2025 (first batch): incorporation and update of initial profiles for 11 jurisdictions, including countries such as Azerbaijan and Pakistan for the first time.
- July 2025 (second batch): publication of updated profiles for 12 other jurisdictions, including Canada, Mexico, Spain, and Singapore, bringing the total to 78 jurisdictions.
- October 2025 (third batch): new block of updates bringing the total to 83 jurisdictions; in addition, the OECD announced that a fourth batch will be published in December to complete the series. These latest updates consolidate and expand key sections such as the treatment of hard-to-value intangibles (HTVI) and the simplified approach for basic marketing and distribution activities (related to Amount B, part of Pillar One of the BEPS 2.0 framework).
The updates are based on official responses from each country to a standardized questionnaire, which seeks to ensure the accuracy and comparability of the information provided.
Why is this list important?
The practical relevance of the Transfer Pricing Country Profiles lies in several key aspects:
- Regulatory transparency: they offer quick and consolidated access to how each jurisdiction regulates and applies transfer pricing, reducing uncertainty for multinational groups.
- Reference for documentation and analysis: they serve as a guide for preparing the master report, local report, and demonstrating the alignment of intra-group policies with local regulations.
- Identification of local risks: they allow the detection of regulatory differences and enforcement priorities that may involve risks of adjustment or controversy.
- Support for dispute resolution: they facilitate the evaluation of positions in MAP procedures and APA requests by showing local administrative practices and precedents.
- Consistency with BEPS initiatives: by including sections on HTVI and simplified approaches linked to Amount B, the profiles help interpret the local implementation of international standards arising from the BEPS project.
Practical implications for companies and advisors
With the expansion to 83 jurisdictions, companies and their consultants should consider specific actions:
- Review transfer pricing policies and documentation for transactions with entities in newly added or updated jurisdictions.
- Update comparability analyses and benchmarks when the country profile reveals changes in preferred methods or market parameters applied by the local administration.
- Assess exposure to HTVI and Amount B, and define documentation and negotiation strategies with tax authorities.
- Prioritize jurisdictions based on material risk and frequency of audits, using profiles as a risk scoping tool.
- Integrate country profile findings into internal audit plans and the preparation of responses to tax requests.
These measures help mitigate adjustment risks and sustain technical defenses in the event of a dispute.
What should tax administrations watch out for?
For administrations, the updates:
- Promote the harmonization of practices and the identification of regulatory gaps.
- Enable improved international coordination for early dispute resolution (MAP/APAs).
- Provide useful information for designing compliance programs and administrative guidelines (e.g., HTVI treatments or the implementation of safe harbors).
The standardized nature of the profiles promotes comparability and supports coordinated actions within the Inclusive Framework.
Conclusion
The 2025 update of the Transfer Pricing Country Profiles reinforces the global commitment to transparency and comparability in transfer pricing. With 83 jurisdictions covered, the OECD profiles are an essential tool for both multinational groups and tax administrations in their quest for consistent application of the arm’s length principle and effective reduction of international disputes.
For companies, regular consultation of the profiles allows them to adapt policies, strengthen documentary defense, and anticipate risks arising from regulatory divergences. In this context, specialized advisors play a key role in translating these standards into practices aligned with the reality of each market.
Does your company correctly apply the OECD guidelines?
At TPC Group, we assist multinational groups and local companies in implementing transfer pricing policies aligned with OECD standards and the regulations in force in each country.
With a presence in Latin America, the United States, and Spain, our multidisciplinary team offers comprehensive solutions that strengthen tax compliance and reduce the risks associated with international adjustments or disputes.
Sources: