Introduction
On 1 June 2026, the OECD published a consultation draft rewriting Chapter VII of the Transfer Pricing Guidelines, the chapter that governs every intra-group service charge within a multinational group. It is the biggest revision in more than a decade. The analysis now follows a new order: the transaction is delineated first, the benefit is tested second, and the price is set third. Agreements, invoices, and fee labels no longer carry the argument. The actual conduct does.
What’s inside
- The five changes every Head of Tax needs to know
- Three case studies: procurement hubs, marketing hubs and digital platforms
- A documentation standard mapped to evidence that organisations already produce
- A 12-month action plan, in sequence
A question for Heads of Tax and CFOs
If an auditor delineated a group’s intra-group service arrangements tomorrow, using only actual conduct and not the agreements, would the cost-plus mark-up survive?
About the research
The World Tax Research Centre (WOTRE) is an initiative of World Tax Lawyers. It brings together academic researchers and practitioners to examine the issues shaping international taxation and transfer pricing.
Get in touch
To discuss this article or any of the issues it raises, please contact Makis Liveras at mliveras@wtlglobal.com.
The Cost-Plus Era for Services Just Ended
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