Introduction

Transfer pricing has evolved beyond traditional transactions. The latest OECD Country Profiles reveal how jurisdictions are approaching hard-to-value intangibles and simplified distribution activities - two areas of increasing importance.

Hard-to-Value Intangibles (HTVI)

Intangibles such as patents, trademarks and proprietary technology pose valuation challenges. OECD Country Profiles now include how countries treat HTVI in their legislation, reflecting work under the OECD/G20 BEPS framework.

Simplified Distribution Rules

Routine distribution and marketing activities often generate low economic value yet incur compliance costs. The updated profiles identify which jurisdictions allow streamlined approaches for such “baseline” functions, reducing administrative burden without compromising compliance.

Why These Trends Matter

• More predictable outcomes for intangible valuations

• Reduced compliance cost for routine distribution functions

• Greater alignment with international BEPS-related transfer pricing work

Conclusion

These trends show how transfer pricing rules are adapting to modern business complexity. For MNEs and advisors, staying updated on such practices, via OECD’s Country Profiles is key to pragmatic transfer pricing strategies.