Behind the Service Label: The OECD’s Proposed Revision of Chapter VII
New
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2026 (Volume 33), No. 6
Document
The proposed chapter VII of the OECD Guidelines on intra-group services integrates accurate delineation into the services analysis and expands guidance on expected benefits, shareholder activities, method selection, intangibles and documentation. The article analyses the proposed changes, outlines relevant observations for taxpayers, and provides examples of potential impacts on the financial services industry.