Intragroup services are one of the areas subject to the highest level of scrutiny in Transfer Pricing. With the aim of updating its guidelines and ensuring more consistent application among tax authorities and taxpayers, the Organization for Economic Cooperation and Development (OECD) launched a public consultation on June 1, 2026 to revise Chapter VII of the Guidelines on Transfer Pricing for Multinational Enterprises and Tax Administrations, which is dedicated to intra-group services.
The comment period will remain open until July 22, 2026. Subsequently, the OECD will analyze the comments received, and the results will be discussed during a public consultation scheduled for November 2026, as part of the process leading up to the publication of the final version of the guidance.
According to the OECD itself, this review does not seek to modify the general principles applicable to intra-group services, but rather to modernize the content of Chapter VII, align it with the rest of the Guidelines, and incorporate practical guidance and examples that promote a more consistent application of the arm’s-length principle.
Key Aspects Under Review
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Definition of Intra-Group Services
The OECD is reviewing the criteria used to determine when a transaction effectively constitutes an intra-group service and how it should be analyzed in accordance with the arm’s-length principle, with the aim of achieving a more uniform application of the Guidelines.
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Determination of the Arm’s-Length Charge
The draft updates the guidance on determining the arm’s-length charge applicable to intra-group services, providing greater clarity on the economic valuation of these transactions between related enterprises.
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Supporting Documentation
The proposal includes specific guidance on the documentation required to support intra-group services, complementing the recommendations set forth in Chapter V of the Transfer Pricing Guidelines.
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New Practical Examples
The OECD has included new examples designed to facilitate the application of the criteria contained in Chapter VII and promote a more consistent interpretation among tax administrations and taxpayers.
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Alignment with the OECD Transfer Pricing Guidelines
Another objective of the revision is to harmonize the treatment of intra-group services with the general principles set forth in Chapters I, II, and III of the Transfer Pricing Guidelines.
What’s Next?
Once the consultation period concludes on July 22, 2026, the OECD will evaluate the comments submitted by businesses, tax administrations, business organizations, and other stakeholders. Subsequently, the comments will be analyzed during the public meeting scheduled for November 2026, prior to the release of the final version of Chapter VII.
Although the document is still under public consultation, this initiative provides insight into the areas where the OECD considers it necessary to strengthen existing guidance. Given that the OECD Guidelines serve as a reference for numerous jurisdictions in Latin America, the outcome of this revision could influence the evolution of tax audit practices and the interpretation of intra-group services in various countries across the region.
The revision of Chapter VII of the Transfer Pricing Guidelines reflects the OECD’s commitment to maintaining a framework aligned with evolving business models and the current needs of tax administrations. Although the public consultation process is still underway, it is advisable for companies with related-party transactions to monitor this initiative, as future changes could influence audit criteria and compliance practices adopted by various jurisdictions, particularly in Latin America.
At TPC Group, we continuously monitor updates issued by the OECD and tax authorities in the region, providing specialized advice on the evaluation, documentation, and defense of related-party transactions. Our team assists corporate groups in adapting to international Transfer Pricing standards, helping to strengthen tax compliance and mitigate risks in the event of tax audits.
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