VSTN Newsletter- Public Consultation Document- OECD-Chapter VII- Intra Group Services
The OECD has recently released a public consultation document proposing revisions to Chapter VII of the #Transfer Pricing Guidelines (TPG) on intra-group services, with comments invited until 22 July 2026. The draft guidelines aim to better align the treatment of intra-group services with the core principles set out in Chapters I to III, while enhancing clarity and consistency in their application.
While the fundamental concepts remain largely unchanged, the draft guidelines strengthen the analytical framework with heightened emphasis on accurate delineation, benefit test, selection of most appropriate method- grounded in economic substance and actual conduct. It further introduces enhanced contemporaneous documentation expectations and includes practical illustrations to support real-world application. These revisions reflect the OECD’s continued focus on substance-based, benefit-driven pricing and aligning transfer pricing outcomes with value creation.
About us
VSTN Consultancy is a Global Transfer Pricing firm with extensive expertise in the field of international taxation and transfer pricing. VSTN Consultancy has been awarded by International Tax Review (ITR) as Best Newcomer in Asia Pacific – 2024 and is ranked as one of the recommended transfer pricing firms. VSTN has also been nominated in 9 Categories under APAC, EMEA and Middle East Region ITR awards 2025. VSTN has its offices in India and Dubai.
Nithya Srinivasan, Founder of VSTN Consultancy, was named Middle East Transfer Pricing Practice Leader of the Year, recognizing her outstanding leadership and contribution to the profession. VSTN also received the Best Newcomer in the Middle East award from International Tax Review, showcasing its rapid growth and excellence in global transfer pricing advisory.
VSTN Consultancy has been honored with the Best Global Transfer Pricing Consultancy 2025 – India award at the prestigious Wealth & Finance Management Consulting Awards 2025.
Our offering spans the end-to-end Transfer Pricing value chain, including design of intercompany policy and drafting of Interco agreement, ensuring effective implementation of the Transfer Pricing policy, year-end documentation and certification, BEPS related compliances (including advisory, Masterfile, Country by Country report), safe harbour filing, audit defense before all forums and dispute prevention mechanisms such as Advance Pricing agreement. VSTNs senior partners have been ranked in ITR in the list of recognized Practitioners.
Locations Served
| Australia | Philippines |
| Belgium | Singapore |
| Denmark | Switzerland |
| India | Turkey |
| Italy | UAE |
| KSA | UK |
| Mexico | USA |
| Netherlands | Zambia |
Our Licensed Databases
| SNo | Database | Provider |
|---|---|---|
| 1 | TP Catalyst | Moody’s |
| 2 | ORBIS | Moody’s |
| 3 | Loan Module | Moody’s |
| 4 | IP & Royalty Data | Moody’s |
| 5 | Royalty Rates and Benchmark Module | ktMINE |
| 6 | Services CUT | ktMINE |
| 7 | EDF-X Bond Database | Moody’s |
| 8 | EDF-X Credit Risk Analytics | Moody’s |
| 9 | Loan Module | Royalty Range |
| 10 | Transfer Pricing Documenter (formerly Thomson Reuters Onesource) | Ryan |
| 11 | Prowess | CMIE |
As businesses expand across borders, navigating complex transfer pricing regulations becomes critical. At VSTN Consultancy, a global transfer pricing firm, we specialize in helping companies stay compliant and competitive across key markets including:
India | UAE | Singapore | USA | KSA | Dubai | Asia Pacific | Europe | Africa | North America
Whether you’re preparing for benchmarking intercompany transactions, or developing robust TP documentation, our team is here to support your international strategy and Compliance.
Contact us today to explore how we can partner with you to optimize your global transfer pricing approach.
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