Netherlands: New transfer pricing decree

New transfer pricing decree focuses on recent developments that have led to changes in the OECD guidelines

New transfer pricing decree focuses on recent developments

A new transfer pricing decree was issued today.

This decree—nr. 2022-0000139020 (dated 14 June 2022)—replaces one from 2018.

Among other things, the new transfer pricing decree focuses on recent developments that have led to changes in the OECD guidelines, but also reflects the effects of the COVID-19 pandemic. Changes from the previous decree include:

  • Significant amendments of the section on financial transactions
  • Amendments to the section on intragroup services
  • Extension of the section on government policy to include a provision on support measures from the government in response to, for example, the coronavirus (COVID-19) pandemic
  • Textual changes to make the terminology more consistent with the terminology as used in the OECD guidelines and Dutch laws and regulations
  • New guidance regarding financial transactions that could affect multinational entities 

Read a July 2022 report prepared by the KPMG member firm in the Netherlands


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