Public consultation on proposed Revisions to Chapter VII of the OECD Transfer Pricing Guidelines

This report by KPMG US provides analysis and observations on the Revisions to Chapter VII and high-level summaries of the 21 examples.

The Organisation for Economic Cooperation and Development (OECD), on 1 June 2026, released proposed 'Revisions to Chapter VII of the OECD Transfer Pricing Guidelines' (Revisions to Chapter VII), covering special considerations for intragroup services. The Revisions to Chapter VII are extensive but leave the conceptual framework for assessing and pricing intragroup services largely unchanged. The Revisions to Chapter VII have five sections (summarised below) and provide 21 examples of how th...

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Published Date: 03 June 2026