This new round covers 12 additional jurisdictions: Austria, Belgium, Canada, Ireland, Latvia, Lithuania, Mexico, the Netherlands, New Zealand, Singapore, South Africa, and Spain.

Key developments include:

• The inclusion of information on Hard-to-Value Intangibles (HTVI);
• The application of the simplified and standardized approach for low-risk marketing and distribution activities (aligned with Amount B under Pillar Two);
• Updates concerning valuation methods, comparability analyses, intra-group services, cost contribution arrangements, documentation, and administrative approaches to dispute resolution.

The initiative seeks to harmonize the global application of the OECD Transfer Pricing Guidelines, fostering greater transparency, predictability, and comparability across jurisdictions.

It should be recalled that, in May 2025, the OECD had already released the first round of updates, which included 11 jurisdictions and, for the first time, the profiles of Azerbaijan and Pakistan.

At that time, the profiles focused on the key aspects of domestic transfer pricing legislation, such as the arm’s length principle, valuation methods, comparability analysis, intangibles, intra-group services, cost-sharing arrangements, documentation, administrative dispute resolution mechanisms, safe harbour regimes, among other implementation tools.

In total, 78 countries and jurisdictions are now covered. The data are provided directly by the jurisdictions themselves, ensuring a high degree of accuracy.

The OECD’s updated Transfer Pricing Country Profiles can be accessed through the following link: Click here

Vella Pugliese Buosi Guidoni Advogados offers specialized advisory services in Transfer Pricing and remains at your disposal to support the analysis and application of the OECD Guidelines in cross-border operations.