Transfer Pricing Q2 Briefing-2026

Welcome to PwC's transfer pricing quarterly briefing. I'm Ian Dikes, PwC's global transfer pricing leader. In this briefing, we highlight selected transfer pricing and tax developments from around the world. We'll begin with the OECD. On June the 1st, the OECD opened a consultation on revisions to chapter 7 of the OECD transfer pricing guidelines. And chapter 7 focuses on intergroup services. The aim is to bring the services chapter up to date to align it with chapters 1 to 3 in particular, which themselves have been updated over the last 10 years. This amounts to a substantial rewrite of the chapter, and it includes 21 examples. It's noteworthy in that the expectation around the kind of evidence of benefit that will be retained and provided are fairly significant. Also, because of the way that without modification, this guidance could open the door to the use of the profit split method for services in situations where most taxpayers will have to date been using a cost plus. So, in particular around high-value services and services relating to IP. It's important to note it's not a consensus document. Uh the consultation closed on the 22nd of July, but there'll be further opportunity to input, and in particular as a public consultation in November. Turning to Japan, the FY26 tax reform bill passed into law on March 31st. Now, this introduces special new provisions on documentation retention requirements for specified intercompany transactions. It applies to transfers of industrial property, which would include most IP, and provision of services, and particularly, but not limited to, services which deploy know-how or IP. So, R& D services, advertising and promotion services are particularly called out. The rules are requiring a clear description of the nature of the services or assets transferred and in particular an explanation of how the payments were calculated. The guidance refers to poorly substantiated charges to Japanese subsidiaries. So, situations where the costs underpinning a recharge are insufficiently detailed or have simply been bundled together. And there's a clear read across there to the chapter seven work that the OECD are doing that we just spoke about. The consequence of failing to provide the requisite detail is revocation of eligibility to file under Japan's preferential tax reporting regime. Finally, in Singapore, on June the 4th, the IRAS released the ninth edition of their transfer pricing guidelines. This update clarifies the treatment of share-based compensation in cost-plus arrangements for intergroup services. Under the guidance, share-based compensation must be included in the entities cost base when calculating the absolute amount of the markup. So, this will apply whether the costs are incurred, uncharged, or simply notional. At the same time, from year of assessment 26 onwards, IRAS have introduced a concession which allows the uncharged and notional share-based compensation to be excluded from the computation of service income. In other words, you include notional and uncharged costs in the cost base when you're working out the amount of the markup, but you won't have to include them in the cost base that you use to calculate the actual invoice value. Anyone with Singapore-based service entities should review whether their calculations and policies align with the new guidance. Thank you for watching. For more information on these developments and other global transfer pricing updates, please refer to the full publication.