The OECD is consulting on revisions to its transfer pricing rules for intra-group services, with proposed updates to Chapter VII of its Guidelines aimed at improving clarity, strengthening alignment with core principles, and adding new practical examples — stakeholders have until 22 July 2026 to submit comments, ahead of a public discussion at the OECD's Paris conference centre in November.
The OECD has opened a public consultation on proposed updates to Chapter VII of its Transfer Pricing Guidelines, which covers the taxation of intra-group services.
The revisions aim to address practical implementation challenges across sectors and regions while strengthening and clarifying the rules through updated guidance and new examples.
Comments are due by 22 July 2026, with a follow-up discussion scheduled for November 2026.
The OECD Committee on Fiscal Affairs has been working to update and modernise the existing provisions in Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG), which provides guidance on intra-group services.
This work aims to ensure alignment between the guidance on intra-group services and the foundational principles in Chapters I, II and III of the OECD TPG. The proposed revisions also seek to further enhance clarity and provide practical illustrations through the inclusion of new examples. The revisions are not intended to change the general principles underlying the transfer pricing analysis of intra-group services.
The OECD recognises the value of receiving input at this stage from a wide range of stakeholders, to consider the ways that the issue presents itself to different groups, industries or across different regions. To this end, a document containing proposed revisions to Chapter VII of the OECD TPG is released for public consultation:
In light of the growing significance of services in cross-border economic activity, guidance on the transfer pricing treatment of intra-group services remains of substantial practical relevance.
Working Party No. 6 (WP6) of the Committee on Fiscal Affairs (CFA) has been working to update and modernise the existing provisions in Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Transfer Pricing Guidelines).
The primary objective of this work is to ensure alignment between the guidance on intragroup services and the foundational principles in Chapters I, II and III of the OECD Transfer Pricing Guidelines.
The revisions also seek to further enhance clarity and provide practical illustrations through the inclusion of new examples. The revisions are not intended to change the general principles underlying the transfer pricing analysis of intra-group services.
This discussion draft presents proposed revisions relating to the accurate delineation of intra-group services, the determination of the arm’s length charge and other conditions for such services, documentation considerations intended to supplement the guidance in Chapter V, and new examples illustrating the application of the principles described in the guidance. The section on “Low value-adding intra-group services” reproduces the existing approach in the OECD Transfer Pricing Guidelines; its content has only been adapted to update cross-references where necessary.
Invitation for comments
Stakeholders are invited to comment on all aspects of this discussion draft, including the extent to which the objectives of this work have been met. The draft includes several specific questions for public commentators on matters for which input will be particularly valuable to WP6 in advancing its work and preparing subsequent iterations of the draft following consideration of the comments received.
Interested parties are invited to submit their comments on this discussion draft by Wednesday, 22 July 2026. Comments should be sent via email to taxpublicconsultation@oecd.org in Word format to facilitate distribution to government officials. Submissions should be addressed to the OECD Centre for Tax Policy and Administration.
The OECD intends to hold a public consultation on this discussion draft in November 2026 at the OECD Conference Centre in Paris, France. Registration details will be published on the OECD website in due course.
Speakers and participants will be selected from among those providing timely written comments. Please be advised that all comments received will be made publicly available. Comments submitted on behalf of a collective “grouping” or “coalition”, or by any person acting to submit comments on behalf of another person or group of persons, should clearly identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.
Status of the discussion draft
The publication of this discussion draft reflects the views of WP6 delegates that this is an appropriate time to invite input from stakeholders, but it does not, at this stage, represent the consensus views of the CFA or its subsidiary bodies that any portion of the content of this draft should be adopted in an updated version of Chapter VII.
This discussion draft is merely intended to provide stakeholders with substantive proposals for potential revisions and additions to the current version of Chapter VII for analysis and comment. Taxpayers and tax administrations should not rely on the approaches discussed in this discussion draft.
