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.
