OECD Consultation On Chapter VII (Intra-Group Services): Submitted Comments And Key Considerations

The submission sets out where the proposed revisions helpfully modernise the guidance on intra-group services, and where further clarification is needed to ensure that the new chapter reduces, rather than increases, the compliance burden and the risk of double taxation for MNE groups.

On 22 July 2026, our Transfer Pricing team submitted its comments to the OECD's public consultation on proposed revisions to Chapter VII of the OECD Transfer Pricing Guidelines, which deals with the special considerations for intra-group services. With intra-group services being among the most common controlled transactions that taxpayers and tax administrations deal with in practice, and among the most frequent sources of controversy, the modernisation of this chapter by Working Party No. 6 is a significant development for MNE groups.