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OECD releases Public Consultation Document on ‘Revisions to Chapter VII of the OECD Transfer Pricing Guidelines’
On 1 June 2026, the Organisation for Economic Co-operation and Development (OECD) released a Public Consultation Document on “Revisions to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations” (2022 OECD Transfer Pricing Guidelines). The proposed revisions address the accurate delineation of intra-group services, the determination of the arm’s-length charge and related conditions, and documentation considerations intended to supplement the guidance in Chapter V. New illustrative examples to aid practical application are also introduced.
Stakeholders are invited to comment on all aspects of the draft, including the extent to which the objectives of this work have been met. The Consultation Document also includes several specific questions for public commentators on matters for which input will be particularly valuable to Working Party 6 (on the Taxation of Multinational Enterprises) in preparing subsequent iterations of the draft. Comments are requested by 22 July 2026, and the OECD intends to hold a public consultation in November 2026.
The Consultation Document states that it reflects the views of the delegates of Working Party 6 but does not, at this stage, represent a consensus view of the OECD’s Committee on Fiscal Affairs or its subsidiary bodies.
For a more detailed discussion: OECD releases Public Consultation Document on ‘Revisions to Chapter VII of the OECD Transfer Pricing Guidelines’.