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OECD: Updated transfer pricing country profiles

Country-specific information on the treatment of hard-to-value intangibles and a streamlined approach for baseline marketing and distribution activities

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May 22, 2025

The Organisation for Economic Co-operation and Development (OECD) today published updated , reflecting the current legislations and practices of 11 jurisdictions, and introduced profiles for Azerbaijan and Pakistan for the first time. These profiles provide country-specific information on the treatment of hard-to-value intangibles and a streamlined approach for baseline marketing and distribution activities.

According to today鈥檚 , the profiles focus on domestic legislation concerning key aspects such as 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 harbour and other implementation measures.

The latest updates include sections on hard-to-value intangibles and streamlined marketing and distribution activities, aligning with the OECD's Two-Pillar Solution addressing digital economy tax challenges.

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