Prix de transfert

OECD releases new transfer pricing profiles for 21 countries


13/12/2021 – The OECD has released the second batch of updated transfer pricing country profiles for Austria, Belgium, Bulgaria, France, Georgia, Germany, Indonesia, Ireland, Italy, Latvia, Malaysia, Mexico, Peru, Poland, Seychelles, Singapore, South Africa and Sweden. Today’s release also includes for the first time country profiles for Albania, Kenya and the Maldives, bringing the total number of countries covered to 63.


The transfer pricing country profiles contain up-to-date and harmonised information on key aspects of transfer pricing legislation and practice, provided by countries themselves in response to a questionnaire. The information on the country profiles reflect the current state of legislation and practice in each country regarding key transfer pricing aspects, including the arm's length principle, methods, comparability analysis, intangible property, intra-group services, financial transactions, cost contribution agreements, documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other simplification measures, other legislative aspects or administrative procedures and attribution of profits to permanent establishments.


The OECD has published transfer pricing country profiles since 2009, providing high-level information about the transfer pricing systems of OECD members and associate jurisdictions. In 2017, the country profiles were significantly modified to reflect the changes resulting from the OECD/G20 Base Erosion and Profit Shifting (BEPS) reports on Actions 8-10 and Action 13 and to accommodate non-OECD member jurisdictions. In August 2021, the OECD released the first batch of updated transfer pricing country profiles, which included new information on the transfer pricing treatment of financial transactions and the application of the Authorised OECD Approach (AOA) to attribute profits to permanent establishments.


Further updates to the transfer pricing country profiles are expected in the first half of 2022.


To access the latest transfer pricing country profiles, visit:


Media queries should be directed to Manuel de los Santos, Acting Head of the Transfer Pricing Unit in the OECD Centre for Tax Policy and Administration (+33 1 45 24 91 42) or to


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