KPMG comments on Proposed Revisions to Chapter VII of the OECD Transfer Pricing Guidelines
KPMG comments generally support revisions, but express concerns about unrealistic expectations for substantiation of expenses.
The OECD on June 1, 2026, released for public consultation Proposed Revisions to Chapter VII of the OECD Transfer Pricing Guidelines covering special considerations for intragroup services.
In response to the request for comments, KPMG tax professionals from KPMG International Limited submitted a memorandum expressing general approval of the efforts made in the Revisions to Chapter VII to clarify how the arm’s length principle applies to intragroup services and to support the deductibility of such charges, but also expressing concern that in some areas the Revisions to Chapter VII lay out unrealistic expectations for the substantiation of intragroup service expenses that may prevent taxpayers from taking deductions to which they should be entitled.