In July 2026, WTS Global submitted comments to the OECD on the public consultation document concerning the proposed amendments to Chapter VII of the OECD Transfer Pricing Guidelines, which addresses special considerations for intra-group services.
Several WTS Global member firms’ tax teams, including Sorainen Latvia and Senior Associate Edgars Hercenbergs in particular, contributed to the preparation of the comments, providing input through joint discussions and consultations on topics including the accurate delineation of services, the benefits test, shareholder and stewardship activities, the cost base and the determination of group charges. The consolidated text was prepared by an editorial team.
Overall, WTS Global’s comments support the OECD’s objective of providing greater clarity on the accurate delineation of intra-group services, the application of the benefits test and the determination of remuneration. At the same time, the comments point out that targeted additions are needed to ensure that the final guidance remains principles-based, proportionate and consistently applicable across different jurisdictions – including by clarifying the approach to routine services, the terminology relating to “stewardship” activities and the proportionality of payment mechanisms.
Read more detailed information and download the comments here.
