The OECD has published more than 100 public comments on proposed revisions to Chapter VII of its Transfer Pricing Guidelines, addressing the arm’s length principle, documentation requirements, and emerging AI-enabled and digital service models.
The OECD published responses to its 1 June 2026 invitation for comments on a public consultation document proposing potential revisions to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations concerning the transfer pricing of intragroup services on 24 August 2026.
The consultation received over 100 public comments from businesses, industry associations, and professional services organisations.
It sought feedback on updating and modernising the existing guidance on applying the arm’s length principle to intragroup services, including more than 20 new examples. The proposed revisions are not intended to alter the general principles underlying the transfer pricing analysis of such services.
Recurring themes included calls for ex-ante application of the benefit test, proportionate documentation requirements, and clearer distinctions between intra-group services and intangible transfers, particularly for AI-enabled and digital service models. Commentators generally supported continued reliance on one-sided transfer pricing methods for most service arrangements.
The OECD will discuss consultation outcomes at a public meeting on 9 November 2026 at the OECD Conference Centre in Paris. Registration details will be published on the OECD website in September 2026.
The public comments are available on the OECD website and can be downloaded here.
Earlier, in June 2026, the OECD opened a public consultation on proposed updates to Chapter VII of its Transfer Pricing Guidelines concerning intra-group services, which ended on 22 July 2026.
