The End of the Cost-Plus 5% Regime for Headquarters? OECD Consultation Paper Looks at Value-Based Pricing of Intercompany Services and Assumes Transfer Pricing Documentation Becomes Audit-Ready

Join our exclusive webinar on The End of the Cost-Plus 5% Regime for Headquarters? OECD Consultation Paper Looks at Value-Based Pricing of Intercompany Services and Assumes Transfer Pricing Documentation Becomes Audit-Ready

The OECD has released a consultation paper proposing significant revisions to Chapter VII of the OECD Transfer Pricing Guidelines on intra-group services. Although the proposals are still under consultation, they signal a clear shift away from treating broad head office charges as routine low value-adding services automatically eligible for a 5% mark-up.

As tax authorities continue to increase scrutiny of management fees and intra-group service arrangements, multinational groups should reassess how services are identified, priced, documented, and supported. The proposals place greater emphasis on accurately delineating services, demonstrating the value they create, and selecting transfer pricing methods that reflect that value.

Join TPA Global for this practical webinar as we explore the potential impact of the OECD proposals and discuss how organisations can prepare for a future where transfer pricing documentation is increasingly expected to be audit-ready.

Why This Webinar Matters

The proposed revisions represent both:

• A compliance challenge
• An opportunity to strengthen transfer pricing governance and documentation

As expectations around service delineation, the Benefit Test, and supporting documentation continue to evolve, organisations must ensure that management fee arrangements accurately reflect the services performed, the value created, and the benefits received.

From distinguishing routine support services from higher-value activities to selecting appropriate transfer pricing methods and maintaining robust documentation, multinational groups will need to adopt a more evidence-based approach to defending intercompany service charges.

What We Will Cover

During this session, we will discuss:

• Why the traditional Cost-Plus 5% approach may no longer be appropriate for many headquarters services
• The OECD’s proposed approach to value-based pricing of intra-group services
• When alternative transfer pricing methods, including CUPs and profit-based approaches, may be more appropriate
• Enhanced Benefit Test requirements and demonstrating services rendered and benefits received
• Managing shareholder costs, duplicative services, and other non-deductible charges
• Why transfer pricing documentation is increasingly expected to be audit-ready
• Practical steps organisations can take to strengthen documentation and prepare for future tax audits

We will also explore the practical implications of the consultation paper and what multinational groups should consider when reviewing existing headquarters charging models.

Who Should Attend?

This session is designed for professionals involved in:

• Heads of Tax
• Heads of Transfer Pricing
• Transfer Pricing Managers
• Tax Directors
• CFOs

As transfer pricing expectations continue to evolve, organisations must ensure that their intercompany service arrangements are commercially supportable, appropriately priced, and backed by robust documentation.