Consultation response to public consulting paper on the OECD Guidelines Chapter VII

Key points from our response:

Chapter VII works well today, and we support keeping its clear and practical approach.
Main concern is para 7.41 example, which risks inferring a "transfer of know-how" just because a service recipient learns from it. If the parties agreed on a service, it should stay a service, and the use of IP should be priced into the fee, not recharacterized.
Shareholder costs have changed over time. Traditionally these excluded activities such as some audit work, ESG reporting, treasury, tax, and some controlling. In our view these services may now also benefit subsidiaries and deserve a fresh look under the benefit test.
Documentation is an easy ask, but a burden for taxpayers. We have cautioned against overly burdensome new requirements such as emails and activity logs that often do not exist in practice, especially for ongoing services.