New Dutch Transfer Pricing Guidance Focuses on Financial Transactions

Clive Jie-A-Joen, M.I.E. (Monique) van Herksen

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Abstract

The Dutch transfer pricing rules were materially updated on July 1, 2022, when a new Dutch transfer pricing decree (Decree No. 2022-0000139020) was published in the Official Gazette.

The changes mainly concern the incorporation of Chapter 10 (on financial transactions) of the 2022 OECD transfer pricing guidelines. The decree also provides for new guidance on the transfer pricing treatment of intragroup financial service entities, the treatment of government support measures in relation to certain events—for example, the Covid-19 pandemic—and the use of an arm’s length range.

There is little doubt that the rules will be applied using a dynamic interpretation, allowing for retroactive effect.

Set out below are a few key aspects of the new decree, particularly with regard to financial transactions.
Original languageEnglish
Number of pages8
JournalTax Management Transfer Pricing Report
Publication statusPublished - 20 Jul 2022

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