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OECD Issues Consultation on TP Guidelines and Intra Group Services

Monday 8th June 2026

The OECD has issued a consultation on proposals to update the existing provisions in Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

The primary objective of this work is to ensure alignment between the guidance on intra-group services and the foundational principles in Chapters I, II and III of the TPG.

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.

The 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.

A section on “Low value-adding intra-group services” reproduces the existing approach in the TPG, with updated cross-references where necessary.

The publication of the discussion draft reflects the views of Working Party 6 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 Committee on Fiscal Affairs or its subsidiary bodies that any portion of the content of the draft should be adopted in an updated version of Chapter VII. The 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.

The OECD invites stakeholders to comment on all aspects of the discussion draft, including the extent to which the objectives of this work have been met by 22 July 2026. 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.

The OECD intends to hold a public consultation on this discussion draft in November 2026 at the OECD Conference Centre in Paris, France.

If you would like more information on the consultation, please contact Keith Rushen on 0207 486 2378.

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