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New Dutch Decree on Application of OECD Transfer Pricing Guidelines

07 July 2022

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Approved Changes

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Netherlands

On 1 July 2022, the Netherlands published Decree No. 2022-0000139020 from the State Secretary for Finance, which provides guidance regarding the application of the arm's length principle and the OECD transfer pricing guidelines. The new Decree replaces Decree No. 2018-6865. Important changes in comparison to the previous decree are mainly in relation to recent changes to the OECD transfer pricing guidelines, as well as transfer pricing considerations in relation to government support measures such as measures for the COVID-19 pandemic. The main changes include: A new Section 9 on Financial Transactions in line with the new transfer pricing guidance on...