KPMG report: Public consultation on proposed Revisions to Chapter VII of the OECD Transfer Pricing Guidelines
KPMG analysis and observations
The OECD on June 1, 2026, released Proposed Revisions to Chapter VII of the OECD Transfer Pricing Guidelines (the “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 and provide 21 examples of how the guidance on intragroup services should be applied.
Read a June 2026 report prepared by KPMG LLP that provides analysis and observations on the Revisions to Chapter VII and high-level summaries of the 21 examples.