The OECD has released a public consultation document, published on 1 June 2026, proposing revisions to Chapter VII of its Transfer Pricing Guidelines, which governs the pricing of intra-group services between members of multinational groups. The work aims to align the guidance on intra-group services with the foundational principles in Chapters I, II and III of the Guidelines and to enhance clarity through new examples, without changing the general principles underlying the transfer pricing analysis of such services.
The draft introduces a more comprehensive framework built around the accurate delineation of intra-group services, the determination of the arm’s length charge, and a dedicated section on documentation and evidentiary considerations. It confirms that cost-based methods should not automatically be treated as the most appropriate pricing method, recognising that more complex approaches such as the profit split may apply where parties make unique and valuable contributions or share economically significant risks.
The OECD has stressed that the document is a discussion draft that does not yet represent a consensus position, so taxpayers should not rely on the proposed approaches at this stage. Stakeholders are invited to submit written comments by 22 July 2026, ahead of a public consultation meeting at the OECD Conference Centre in Paris in November 2026.