We provide a wealth of publications by PwC Uganda providing informed commentary on current developments in the tax and legal arena, both locally and internationally.
Through analysis and comment on new law and judicial decisions of interest, they assist business executives to identify developments and trends in tax law and revenue practice that might impact their business.
In this issue:
Tax Alert - OECD rewrites the rules on intra-group services
The OECD has released a public consultation draft proposing revisions to Chapter VII of the OECD Transfer Pricing Guidelines, which addresses intra-group services. The consultation paper is open for comments until 22 July 2026, with a public consultation planned for November 2026. The paper aims to align Chapter VII with the core transfer pricing principles set out in Chapters I–III while preserving the existing framework and underlying principles.
The proposed updates introduce enhanced practical guidance and illustrative examples to help taxpayers and tax authorities apply the arm’s length principle consistently when assessing intra-group service arrangements. The revisions are particularly relevant in today’s increasingly complex multinational operating environment, where shared services, centralized functions, and cross-border support activities continue to grow.
For Ugandan taxpayers engaged in intra-group service transactions, the proposed changes may influence transfer pricing documentation, service charge allocation methodologies, and the demonstration of economic benefit received. Businesses should assess the potential impact of the draft guidance and consider participating in the consultation process where appropriate.
Please find our latest alert for further insights.
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