Few items on a multinational’s transfer pricing return draw more audit scrutiny than how a group charges its own entities for services. On June 1, 2026, the Organization for Economic Cooperation and Development (OECD) released Public Consultation Document, Revisions to Chapter VII of the OECD Transfer Pricing Guidelines: Special considerations for intra-group services. The OECD’s stated aim is to modernize the chapter and align it with the core principles of Chapters I–III, not to change the underlying analysis. For multinational groups, the draft is best read as an early indication of how tax authorities will expect intra-group service charges to be analyzed and supported. It represents a practical checklist against which to review existing arrangements now, well before the guidance is finalized.

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