Transfer Pricing Trends: Moving Toward Greater Global Consistency

2025 is shaping up to be a pivotal year in the evolution of transfer pricing rules globally. Recent releases from the OECD and developments in international enforcement point to growing unification and standardisation.

Below is a summary of the developments likely to shape year-end 2025 and early 2026.

OECD updates transfer pricing profiles for 25 jurisdictions

On 22 October 2025, the OECD published the third batch of country transfer pricing profiles, covering 25 new or updated jurisdictions. With this release, coverage has expanded to 83 jurisdictions, and a fourth batch is expected in December 2025.

Key changes include:

• Inclusion of countries such as Guatemala, Thailand, the United Arab Emirates, and Zambia, strengthening geographic coverage.
• Updates to sections on hard-to-value intangibles (HTVI) and the simplified approach for baseline marketing and distribution activities.
• Cross-references aligned with BEPS 2.0 standards.

This expansion facilitates jurisdiction-to-jurisdiction comparison and underscores the need to align global TP policies.

Australia: convergence between transfer pricing and customs valuation

On 10 October 2025 in Sydney, the Transfer Pricing for the International Practitioner 2025 forum gathered representatives from the Australian Taxation Office (ATO) and the Australian Border Force to discuss growing coordination between TP and customs valuation.

Highlights:

• The need for consistency between import values and TP margins, especially for global supply chains.
• The importance of reviewing internal policies ahead of the OECD’s Amount B application expected in 2026.

This interaction reflects a broader trend toward integrated oversight of intercompany transactions, particularly around arm’s-length valuation of imported goods.

International enforcement: stronger criteria and documentation

Throughout Q4 2025, multiple tax authorities have intensified reviews of documentation and TP adjustments, with increased focus on:

• Consistency across the Local File, Master File, and CbC reports, increasingly examined together.
• Detailed review of financial transactions and intangibles, particularly in a high-interest-rate environment.
• Adoption of simplified approaches inspired by Amount B for routine distributors and service providers.

These trends point to a more coordinated global system, seeking uniform application of the OECD Guidelines in practice.

Conclusion. Year-end 2025 shows strong momentum toward international harmonisation of transfer pricing policies. Expanded OECD coverage and growing inter-authority coordination reinforce the need for multinational groups to ensure alignment across margins, documentation, and internal policies.

At ALS Transfer Pricing, we continuously monitor these developments to provide up-to-date advice aligned with global best practices.