Introduction
At the heart of international transfer pricing is a set of core principles and methods recognized across jurisdictions. The OECD Country Profiles distil these fundamentals and show how different countries implement them.
The Arm’s-Length Principle
This foundational concept requires related parties to price transactions as independent entities would. Nearly all country profiles anchor their systems to this principle, following the OECD Guidelines.
Accepted Transfer Pricing Methods
Countries typically recognise:
Comparable Uncontrolled Price (CUP)
Resale Price Method
Cost-Plus Method
Transactional Net Margin Method
Profit Split Method
Profiles indicate which methods are preferred or mandated locally.
Documentation & Compliance
Most jurisdictions require contemporaneous documentation demonstrating transfer pricing analysis, benchmarking, economic justification and functional analysis, mirroring OECD-derived standards.
Conclusion
For multinational enterprises, mastering these key principles through the lens of OECD Country Profiles enhances transfer pricing compliance and reduces audit risk, especially in complex, multi-jurisdictional scenarios.
