The OECD published the third batch of updated transfer pricing country profiles on January 16, 2026, continuing the rolling update programme that began with the first batch in 2023 and the second batch released on October 22, 2025. The country profiles set out the legislative and administrative position of each participating jurisdiction on key transfer pricing topics.
The latest update extends coverage of two areas that have been progressively built into the country profile template. The first is the application of the Hard-to-Value Intangibles (HTVI) approach under Chapter VI of the OECD Transfer Pricing Guidelines. The second is the implementation of the simplified and streamlined approach to baseline marketing and distribution activities under Pillar One Amount B, which jurisdictions can elect to apply for fiscal years beginning on or after January 1, 2025.
Practitioners working on benchmarking studies and transfer pricing documentation across multiple jurisdictions can use the country profiles as a starting reference for the local position on these topics, although the underlying domestic legislation and administrative guidance remain the controlling source. The OECD has indicated that further batches of updates will follow, with the eventual goal of refreshed coverage across all Inclusive Framework jurisdictions.