OECD Intragroup Services Update Needs Better Real-World Examples, Bloomberg Tax

Partners Thomas Linguanti and Drew Cummings co-authored an article for Bloomberg Tax analyzing the Organisation for Economic Co-operation and Development’s (OECD’s) proposed revisions to its transfer pricing guidelines for intragroup services and the implications for multinational enterprises.

The authors examine how the proposed guidance addresses complex cross-border service arrangements involving intangible assets, economically significant risks, and contributions from multiple jurisdictions, while identifying areas where greater clarity is needed. They recommend that the OECD incorporate more practical, multijurisdictional examples to help businesses determine appropriate transfer pricing methods, anticipate differing tax authority interpretations, and mitigate audit and dispute risks.

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