The OECD launched a public consultation Monday focused on updating transfer pricing guidance to clarify existing principles and provide practical examples for identifying and pricing intragroup services.
The proposed update to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations seeks to amend the accurate delineation of intragroup services and the determination of transfer pricing methods where they have been identified.
Intragroup services arise where one group company performs activities that provide a clear economic or commercial benefit to another group company such that, in comparable circumstances, an independent enterprise would be willing to pay ...