BorderCrossings with EY transfer pricing and tax professionals - July 2026

Service fees in the spotlight - OECD’s new draft explained

The July BorderCrossings webcast will address the latest public consultation (2026 Consultation) draft from the Organisation for Economic Co-operation and Development (OECD) clarifying existing guidance on the pricing of intercompany services transactions, which could cause companies to reevaluate the arm’s length nature of such transactions. As companies transition to high-value, intangible-embedded services and other methods to allocate profits in an integrated business model, they will need to assess whether the pricing of their intercompany service fees is aligned with this draft guidance.

Panelists will discuss:

• The ways in which the 2026 Consultation on “Revisions to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations” reinforces guidance issued in 2022 on the continued importance of documentation and allocation keys when pricing services
• The differences in the 2026 Consultation from the 2022 Transfer Pricing Guidelines
• The new examples in the 2026 Consultation highlighting the role of high-valued services where a cost-plus-based method may no longer apply, including deference to Chapter VI guidance where intangibles may be embedded in services

Learning objectives

Review the OECD draft guidelines on service fees; analyze the similarities and differences from previous guidance; discuss new examples.

Panelists

• Ronald van den Brekel, EY Global Transfer Pricing Market and Innovation Leader; Partner, International Tax and Transaction Services, EY Belastingadviseurs B.V.
• Jonathan Thompson, Principal, Financial Services Transfer Pricing, Ernst & Young LLP (US)
• Bill Morgan, Managing Director, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP (US)

Moderator

• Sirsha Chatterjee, Principal, Transfer Pricing, International Tax and Transaction Services, Ernst & Young LLP (US)

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax.