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Netherlands Not Implementing Pillar 1 Amount B but Accepting Amount B Outcomes in Covered Jurisdictions

27 December 2024

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Approved Changes

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Netherlands

The Dutch State Secretary for Finance recently issued a decree regarding the implementation of Amount B relating to the simplification of transfer pricing rules under Pillar 1. Amount B provides a simplified and streamlined approach for pricing certain controlled transactions involving baseline marketing and distribution activities. According to the decree, the Netherlands will not implement Amount B for domestic taxpayers engaged in routine marketing and distribution activities. However, the Netherlands has committed to accepting the outcome of the application of Amount B when applied correctly by an affiliate in a covered jurisdiction that has implemented Amount B and has a...