On 1 June 2026, the OECD released a discussion draft proposing revisions to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises, addressing the transfer pricing treatment for intra-group services. The proposal reflects the growing significance of such services in cross-border business.
The draft covers the accurate delineation of intra-group services, the determination of the arm's length charge, documentation considerations, and new illustrative examples. It is important to note that the discussion draft does not aim to change the fundamental principles, but to modernise the existing guidance and to ensure closer alignment with the core principles set out in introductory chapters of the OECD Transfer Pricing Guidelines.
In connection with the publication of the discussion draft, the OECD invited stakeholders to provide input and comments. A significant number of comments have been received. These will, together with the discussion draft, be considered at a public consultation meeting in November for further work by the OECD.
The discussion draft does not, at this stage, reflect a consensus view within the Committee, and tax administrations are advised by the Committee not to rely on the approaches discussed in the draft.
It will be interesting to follow the OECD’s ongoing work. We do not expect an update or revision of the guidelines before the end of the year.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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