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An overview from Garrigues, Taxand Spain
The OECD has launched a public consultation on proposed revisions to Chapter VII of its Transfer Pricing Guidelines relating to intra-group services, with comments invited until 22 July 2026.
The proposed revisions are intended to modernise the existing guidance, improve clarity and provide additional practical examples without changing the underlying arm’s length principles. The draft also signals a more flexible approach to analysing intra-group services, placing greater emphasis on reasonably foreseeable benefits and reducing reliance on automatic adjustments.
Miguel Hernández Ruiz from our Spanish member firm, Garrigues, explores the proposed changes and their potential implications, which you can read here.
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