The Organisation for Economic Co-operation and Development (OECD) closes its public consultation on Wednesday, July 22, to modernize Chapter VII of its Transfer Pricing Guidelines. The document introduces five structural changes to the rules governing tax deductibility of services rendered between subsidiaries of multinational groups.
Open for comment since June 1, the review updates the criteria for determining when an intragroup service is genuinely deductible and under what conditions. The document raises documentation requirements and aligns intragroup-services guidance with the general transfer pricing principles the OECD established in earlier reforms. For Mexico, the adjustment arrives at a moment of heightened tax scrutiny. According to the Instituto Mexicano de Ejecutivos de Finanzas (IMEF), audit activity by the Servicio de Administración Tributaria (SAT) on related-party transactions has increased significantly, making the new international standard a reference that Mexican tax authorities typically incorporate into their enforcement criteria.
The consultation document proposes five core modifications:
- Raised benefit test: companies must demonstrate with evidence that the service generated real economic value for the recipient entity, as if that entity had contracted it from a third party.
- Elimination of the mark-up on pass-through costs: where the parent acts solely as a payment intermediary, costs are transferred with no profit.
- Strict delimitation of shareholder activities: board meetings, financial consolidation, and parent-company obligations are absorbed 100 percent by the head office.
- Fixed 5 percent mark-up for low-value-added services, with no benchmarking study required.
- Mandatory advanced methods for services involving intangibles or shared risks, discouraging automatic use of cost plus.
Following the close of the comment period, the OECD will hold in-person roundtables in November 2026, and the final version of the guidelines will be published once that process concludes. For companies with operations in Mexico, the timeline offers a concrete window to adjust transfer pricing policies before the new standard is reflected in SAT enforcement criteria.
This article was drafted with artificial intelligence assistance from verified sources and reviewed by a human editor before publication.