On June 1st, 2026, the OECD released a public consultation document proposing a comprehensive revision of Chapter VII of the OECD Transfer Pricing Guidelines on intra-group services. While the consultation is presented as a clarification and consolidation of existing guidance, the proposed changes would strengthen the analytical and evidentiary requirements for applying the arm’s-length principle to intra-group services. In particular, the draft introduces new rules regarding accurate delineation, the benefit test, contemporaneous documentation, and the assessment of related transactions. This article examines the key proposals and considers their practical implications for multinational enterprise groups and tax administrations.
