The OECD has released draft revisions to Chapter VII of its Transfer Pricing (TP) Guidelines for public consultation, focusing on intra-group services. The proposed changes aim to clarify certain aspects and provide practical examples where the existing guidance has proven unclear in practice. The need for these revisions highlights the increasing complexity of TP rules and the fact that they are often not sufficiently clear for practical implementation.

The draft places greater emphasis on demonstrating that intra-group services have actually been rendered as a precondition for any TP charge and it also underscores the importance of properly identifying shareholder activities for which no TP charge is permitted — areas that have historically often not been given adequate attention.

Interested parties are invited to submit their comments on this discussion draft by Wednesday, 22 July 2026. Rising complexity remains a challenge, but these developments offer a path towards clearer interpretation — and those who are timely informed and prepared will have the advantage.