The Organization for Economic Cooperation and Development (OECD) continues to expand and update its Transfer Pricing Country Profiles, a reference tool that summarizes how each jurisdiction applies transfer pricing rules within its domestic regulatory framework. On January 22, 2026, the fourth batch of updates to these profiles was published, completing the series of publications for the 2025 cycle.
What are the Transfer Pricing Country Profiles?
The Country Profiles are technical fact sheets for each country that describe the main characteristics of each jurisdiction’s transfer pricing regime, with a focus on:
- application of the arm’s length principle,
- methods recognized by local regulations,
- comparability analysis,
- treatment of intangibles and intra-group services,
- documentation and administrative approach to disputes,
- mechanisms such as safe harbors, advance pricing agreements (APAs), among others.
The objective is to provide consolidated, standardized, and comparable information on the rules in force in each country, based directly on official responses from tax administrations to standardized OECD questionnaires.
What does the “fourth batch” of updates represent?
The 2025 update has been carried out in several batches throughout the year, integrating both revisions and new additions. In the most recent cycle:
- In January 2026, the OECD published the fourth batch of updates, which includes updated information on the profiles of: Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Greece, Iceland, Korea, and Norway.
With the third batch published on October 22, 2025, the total number of jurisdictions covered rose to 83. The fourth batch (January 2026) completed the series of updates planned for the 2025 cycle.
Why is it significant that countries are updated and added?
The periodic updating of these profiles is not just a technical exercise: it has real implications for multinational companies and tax advisors:
1. Reflection of global regulatory dynamics
Transfer pricing legislation is constantly evolving. Updating the profiles allows us to see how each country incorporates components of international standards, such as the approach to hard-to-value intangibles (HTVI) or the simplification for basic marketing and distribution functions (related to Amount B of Pillar One of BEPS 2.0).
2. Documented comparative basis
Having updated profiles makes it easier for companies and advisors to:
- identify real differences between jurisdictional frameworks,
- understand which methods and requirements apply locally,
- compare administrative and operational practices,
- design transfer pricing policies consistent with the expectations of tax authorities.
3. Support for risk analysis and defenses
When a multinational group prepares for an audit, having a reliable and comparable source of information on how each country treats key transfer pricing issues reduces uncertainty and allows for the construction of robust defenses regarding the choice of methods, treatment of intangibles, and associated documentation.
4. Improved transparency and regulatory convergence
The incorporation of new countries—especially those outside the traditional OECD core—contributes to greater convergence in the application of international principles and promotes predictability in increasingly interconnected global markets.
Continued importance of Country Profiles
Since their launch in 2009, the Transfer Pricing Country Profiles have evolved to incorporate regulatory changes resulting from global initiatives such as the OECD/G20 BEPS project, while also integrating new sections on specific transactions and administrative aspects.
Today, this tool is one of the most comprehensive references for international regulatory comparability, allowing both tax administrations and taxpayers to access a standardized view of the transfer pricing regimes in force in multiple jurisdictions.
Conclusion
The fourth round of updates to the OECD’s Transfer Pricing Country Profiles represents another step forward in the quest for transparency and regulatory consistency in the field of transfer pricing. The inclusion of new countries and the constant review of existing frameworks provide multinational companies, tax teams, and advisors with an accurate and comparable tool for evaluating legal frameworks, identifying risks, and aligning internal policies with global regulatory expectations.
Strategic advice on new international transfer pricing standards
In a context in which the OECD continues to expand and deepen the information available on transfer pricing regimes globally, having a specialized analysis is key to proper tax risk management.
At TPC Group, we assist business groups in evaluating, implementing, and defending their transfer pricing policies, taking into account both OECD standards and the specific regulations of each jurisdiction.
If your company operates in multiple countries or is evaluating new compliance obligations, our team can provide you with comprehensive support.
Source: OECD