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 a conceptual evolution in the application of the traditional benefit test towards a more substance- and value-creation-oriented framework centred on accurate delineation, economic reality and the contribution of services to the MNE group’s value chain.
No takes yet. Share an insight, caveat, or question.
Mirna Screpante (2026) studied this question.
Synapse has enriched 5 closely related papers on similar clinical questions. Consider them for comparative context: