The OECD has launched a public consultation on proposed revisions to Chapter VII of the OECD Transfer Pricing Guidelines, which contains guidance on the transfer pricing treatment of intra-group services. The revisions seek to modernise the chapter and align it more closely with the general transfer
BRUSSELS | 8 JUNE 2026
OECD Launches Consultation on Revised Transfer Pricing Guidelines on Intra-Group Services
The OECD has launched a public consultation on proposed revisions to Chapter VII of the OECD Transfer Pricing Guidelines, which contains guidance on the transfer pricing treatment of intra-group services. The revisions seek to modernise the chapter and align it more closely with the general transfer pricing framework in Chapters I–III of the Guidelines, while preserving the existing arm’s length principles. A key focus of the draft is expanded guidance on the application of the benefit test and the accurate delineation of intra-group service transactions. The OECD proposes clarifications on when an activity provides economic or commercial value to a group member and confirms that a reasonable expectation of benefit may be sufficient, even where anticipated benefits do not ultimately materialise. Additional examples are provided on shareholder activities, duplicative services, incidental benefits and on-call services. The draft also includes updated guidance on transfer pricing methodologies, emphasising that no presumption exists in favour of cost-based pricing methods and that the most appropriate method should be selected based on the facts and circumstances of the transaction. New examples address service arrangements involving intangibles, research and development, data analytics and AI-related activities. The consultation seeks stakeholder input on several specific issues, including the scope of shareholder activities, the use of allocation keys for shared service arrangements, and the treatment of stock-based compensation in transfer pricing analyses. The OECD is also proposing a new documentation section outlining evidence that may be used to demonstrate the existence of services and compliance with the benefit test. The simplified approach for low value-adding intra-group services, including the 5% mark-up, is largely retained. Comments on the consultation document are invited until 22 July 2026 via email to taxpublicconsultation@oecd.org, with submissions requested to be provided in Word format. A public consultation meeting scheduled for November 2026 in Paris. Registration details concerning the consultation will be published on the OECD website in due course.
EU AMLA Publishes Draft Guidelines for Ongoing Monitoring of Business Relationships
The EU Anti-Money Laundering Authority has launched a public consultation on draft Guidelines concerning the ongoing monitoring of business relationships under Article 26(5) of the Anti-Money Laundering Regulation (AMLR). The consultation is open until 3 September 2026, with a public hearing scheduled for 2 July 2026. The final Guidelines are expected to be issued in the fourth quarter of 2026. The draft Guidelines seek to promote a consistent, risk-based and proportionate approach to ongoing monitoring across both financial and non-financial sectors. AMLA emphasises that ongoing monitoring extends beyond transaction monitoring and includes the review of customer activities, behaviours and changes in circumstances throughout the course of a business relationship. The Guidelines are intended to apply horizontally to all obliged entities under the AMLR, including newly in-scope sectors such as crowdfunding service providers, investment migration operators, football clubs and agents, certain crypto-asset service providers, credit intermediaries and traders in high-value goods. The Guidelines are structured around two core areas. The first concerns keeping customer information up to date through periodic reviews and event-driven reviews. Obliged entities would be required to apply a risk-based approach when determining the scope and frequency of customer information updates, taking account of the customer’s risk profile and any changes in circumstances. AMLA proposes that expired identity documents should not automatically require re-collection; instead, obliged entities should assess whether updates are necessary based on risk factors such as the customer’s risk profile, the length of document expiry and the reliability of existing information. The second part of the draft Guidelines addresses transaction and activity monitoring frameworks. Obliged entities would be expected to implement monitoring systems capable of identifying unusual or suspicious transactions and activities, using manual, automated or semi-automated processes depending on the nature, complexity and risk profile of their business. AMLA stresses that monitoring frameworks should be integrated with customer due diligence processes, regularly tested and reviewed, and capable of identifying evolving money laundering and terrorist financing risks. The Guidelines also encourage the use of advanced analytical tools, including artificial intelligence, where appropriate, while emphasising the need for governance, explainability and human oversight. Stakeholders are invited to provide feedback on the draft Guidelines via the AMLA website consultation page until 3 September 2026.
FISC Hearing on Reverse Charge Mechanism in Fight Against VAT Fraud
The European Parliament Subcommittee on Tax Matters held a public hearing on 2 June 2026 examining the effectiveness of the reverse charge mechanism in combating VAT fraud, particularly Missing Trader Intra-Community fraud. The discussion focused on the future of the mechanism under Articles 199a and 199b of the VAT Directive, which remain in force until 31 December 2026, and its role within broader efforts to reduce the EU VAT gap, estimated at approximately €128 billion annually. Expert speakers acknowledged that the reverse charge mechanism has been effective in addressing certain forms of VAT fraud, particularly in sectors such as construction, mobile devices and greenhouse gas emissions trading. However, it was also characterised as an exceptional and temporary measure that departs from the normal functioning of the VAT system. Concerns were raised regarding the administrative burden and compliance costs associated with maintaining parallel VAT collection processes, with references made to estimates that such costs amount to more than €5 billion across the EU. The hearing highlighted the importance of the VAT in the Digital Age reforms, including the introduction of mandatory digital reporting requirements for cross-border transactions from 2030. Speakers noted that real-time transaction reporting could significantly improve the detection of fraudulent activity and reduce reliance on reverse charge mechanisms over the longer term. Nevertheless, participants observed that full harmonisation of reporting systems across Member States is unlikely before 2035, suggesting that interim anti-fraud measures may continue to be required. A case study from Spain’s fuel sector illustrated the limitations of the reverse charge mechanism in addressing sophisticated organised fraud schemes. Spanish authorities instead relied on measures including supplier guarantees, joint and several liability provisions, monthly VAT settlements and near real-time invoice reporting through the SII system, which contributed to the dismantling of a network of fraudulent companies. Several speakers emphasised that broader VAT harmonisation remains essential to tackling fraud and reducing compliance burdens. Divergent VAT rates and administrative requirements across Member States were identified as continuing obstacles to the functioning of the Single Market, with calls for simpler and more uniform VAT rules alongside enhanced digital reporting capabilities. The FISC meeting also considered amendments to the draft report on the feasibility of a “28th tax regime” to support EU competitiveness and discussed the draft report on the EU’s approach to corporate tax policy in a changing international environment. The latter examines the implications of the OECD/G20 Inclusive Framework agreement on a “Side-by-Side” approach to minimum taxation and highlights concerns regarding competitiveness, complexity and the future of international tax cooperation. Amendments to the corporate tax policy report may be tabled until 9 June 2026, with a vote expected at a subsequent meeting.
ECJ Rules VAT Adjustment May Be Subject to Additional Procedural Conditions in G Kft Case T-198/25
The General Court of the Court of Justice of the European Union delivered its decision in Case T-198/25, G Kft. v Hungarian Tax Authority this week. The General Court in the decision considered whether EU law permits national rules restricting the adjustment of VAT incorrectly invoiced after a tax inspection has been completed. The case concerned a Hungarian company that had charged VAT on deposit transactions subsequently determined not to fall within the scope of VAT. Following the closure of a tax inspection covering the relevant period, the company sought to reopen the period in order to adjust VAT that had not previously been corrected. Under Hungarian law, a tax period already closed by an inspection may only be reopened where the taxpayer can demonstrate a new fact or circumstance capable of altering the findings of the earlier inspection and which was not previously known, nor could reasonably have been known. The tax authorities rejected the company’s request on the basis that the information relied upon did not satisfy those conditions. The Court recalled that Member States may establish procedural rules governing the adjustment of VAT incorrectly invoiced, provided those rules comply with the principles of effectiveness, fiscal neutrality and proportionality. It found that the Hungarian legislation did not make the exercise of the right to adjustment excessively difficult, since the taxpayer had a reasonable opportunity to correct the VAT position before the audit, during the audit, or by challenging the audit outcome. The Court therefore held that EU law does not preclude national legislation requiring a taxpayer to demonstrate a new fact capable of altering the findings of a completed tax inspection before a closed period may be reopened, even where there is no risk of loss of tax revenue, provided the taxpayer has already had a reasonable opportunity to exercise the right to adjustment. The judgment confirms that Member States may impose additional procedural requirements on VAT adjustments in the interests of legal certainty, provided those requirements do not make the exercise of EU law rights excessively difficult in practice.
OECD Tax & Development Days: 17 & 18 June 2026
The OECD will host the Tax and Development Days 2026 as a online virtual event spread across two days, from 17–18 June 2026. The event will bring together policymakers, tax administrations, international organisations, businesses and civil society representatives to discuss how tax systems can better support sustainable development. Held under the theme “From Rules to Results: Turning Tax Policy into Development Impact”, the event will examine how greater tax certainty, simplified tax rules, stronger tax administration, improved transparency and the effective use of data can help developing countries strengthen domestic revenue mobilisation and support economic growth. The programme is structured around several thematic areas. Sessions on tax certainty and simplification will address transfer pricing, mutual agreement procedures, and recent developments relating to the Global Minimum Tax, with a focus on balancing revenue mobilisation, investment and administrative efficiency. Discussions on tax administration will cover the International Survey on Revenue Administration, the OECD’s Virtual Training to Advance Revenue Administration programme, and approaches to improving VAT compliance in the digital economy. Additional sessions will focus on trust, transparency and tackling tax crime, including tax morale, illicit financial flows, social protection financing in highly informal economies, and capacity-building for exchange of information. A separate stream on data for better tax policy will explore the use of revenue statistics, taxpayer data protection, tax incentives evaluation and the role of tax instruments in supporting emissions reduction objectives. The programme will also highlight OECD development initiatives and partnerships, including Tax Inspectors Without Borders and collaboration with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development, aimed at strengthening tax capacity and improving tax outcomes in developing countries. Registration for the event is possible via the links contained in the programme here.
The selection of the remitted material has been prepared by: Dr. Aleksandar Ivanovski & Brodie McIntosh
Fonte: CFE Tax Advisers Europe. Pubblicazione originale del 2026-06-08.