The OECD held a public consultation meeting on 9 November 2026 to discuss stakeholder feedback on proposed revisions to Chapter VII of its Transfer Pricing Guidelines, covering the benefit test, service charges, transfer pricing methods and documentation requirements.
The OECD held a public consultation meeting to discuss proposed revisions to Chapter VII of its Transfer Pricing Guidelines on intra-group services on 9 November 2026, following the release of the consultation document in June 2026.
Earlier, in October 2026, the OECD scheduled a public consultation meeting for 9 November 2026 to discuss proposed revisions to Chapter VII of its Transfer Pricing Guidelines on intra-group services, focusing on stakeholder feedback and the potential implications of the proposed changes.
The OECD is updating Chapter VII of the Transfer Pricing Guidelines, the chapter on intra-group services, so it lines up with the principles in Chapters I, II and III. The draft adds new examples and aims for clearer wording, but it does not change the underlying principles of the transfer pricing analysis for these services. A discussion draft went out for comment in June 2026, and the meeting covers both that draft and the comments received.
Agenda
All times are in CET/UTC +1 (Paris, France). The meeting runs on Monday, 9 November 2026, 9:00 to 17:30, at the OECD Conference Centre in Paris. Its purpose, per the “About” section, is to discuss the proposed revisions to Chapter VII (intra-group services) and the public comments received.
09:00 to 09:15: Welcome and opening remarks
Manal Corwin, Director, Centre for Tax Policy and Administration, OECD.
9:15 to 9:45, Session 1: General remarks
Speakers give overarching comments on the general direction of the Chapter VII revisions. Since the revisions are meant to align the chapter with Chapters I to III, this session sets the frame for the detailed sessions that follow.
9:45 to 10:40, Session 2: Accurate delineation of the transaction and the benefit test
This is the session that ties directly to the alignment goal. It looks at how accurate delineation of the transaction under Chapter I interacts with the benefit test under Chapter VII. It also covers how the benefit test is defined, including the notion of expected benefit. Selected examples are discussed.
11:00 to 11:40, Session 3: Shareholder activities and incidental benefits
The session covers the types of activities that are not considered to meet the benefit test, which links it back to Session 2. It also takes up the questions to commentators on page 12 of the public consultation document regarding shareholder activities. Selected examples are discussed.
11:40 to 12:45, Session 4: Provision of services in connection with other transactions (focus on delineating intangible transactions versus services)
The focus is on the delineation between service transactions and intangible transactions. Selected examples are discussed. This is the longest of the topical sessions, at 65 minutes.
14:00 to 14:45, Session 5: Charging approaches and allocation keys
The session covers the pricing of intra-group services, including direct and indirect charging methods. It also covers allocation keys and the questions to commentators on page 18 of the public consultation document. Selected examples are discussed.
14:45 to 15:40, Session 6: Transfer pricing methodologies including cost base and pass-through costs
Discussion starts with selecting the most reliable transfer pricing method. It then moves to the cost base and related points: pass-through costs and share-based remuneration. The questions to commentators on page 20 of the public consultation document are included. Selected examples are discussed.
16:10 to 17:20, Session 7: Documentation and other issues
The session covers the documentation section of the public consultation document. It is framed as an open dialogue between business, accounting firms and governments on how best to balance documentation requirements for service transactions. Selected examples are discussed.
17:20 to 17:30, closing remarks
Manuel de los Santos, Head of the Transfer Pricing, Tax Treaties and International Agreements Division, OECD.
Sessions 2 to 7 each include selected examples. Speakers come from business associations, the Big Four and other advisory firms, law firms, economic consultancies and one company (AstraZeneca). Lunch ran from 12:45 to 14:00, with coffee breaks at 10:40 and 15:40.
Comments received
The OECD published the public comments on 24 August 2026, and they feed directly into the November discussions.
