OECD Seeks Comments on Proposed Amendments to Transfer Pricing Guidelines for Intra-Group Services

The Organization for Economic Cooperation and Development (OECD) June 1 opened a consultation on proposed amendments to the transfer pricing guidelines for intra-group services. The proposals include measures to: 1) align the provisions with other foundational transfer pricing principles in the guidelines; 2) update rules for accurately delineating services, applying the benefit test, and assessing whether services have been rendered; 3) amend the rules for determining arm’s-length pricing and other conditions, including direct and indirect charge approaches, transfer pricing methods, and the treatment of pass-through costs; 4) update documentation requirements; and 5) revise the guidance on low value-adding intra-group services ...