From Benefits to Value Creation: Rethinking the Arm’s Length Principle for Intra-Group Services under the OECD’s Proposed Revision of Chapter VII
The OECD’s 1 June 2026 public consultation document proposing revisions to chapter VII of the Transfer Pricing Guidelines represents a significant reconsideration of the framework for intra-group services since the post-BEPS Transfer Pricing Guidelines 2017. T