From Benefits to Value Creation: Rethinking the Arm’s Length Principle for Intra-Group Services under the OECD’s Proposed Revision of Chapter VII

The OECD’s 1 June 2026 public consultation document proposing revisions to chapter VII of the Transfer Pricing Guidelines represents a significant reconsideration of the framework for intra-group services since the post-BEPS Transfer Pricing Guidelines 2017. The proposed draft reflects aconceptual evolution in the application of the traditional benefit test towards a more substance- andvalue-creation-oriented framework centred on accurate delineation, economic reality and the contribution of servicesto the MNE group’s value chain.