Effective as of 1 January 2022, legislation was implemented in the Dutch Corporate Income Tax Act 1969 (CITA) to end unilateral downward transfer pricing adjustments.Specifically, article 8bd CITA was introduced, preventing double non-taxation due to a valuation difference between jurisdictions in situations involving certain capital transactions such as contributions or distributions.On 24 January 2023, the Dutch State Secretary of Finance published a Decree clarifying the application and scope of article 8bd, paragraph 1 CITA.Executive summaryThe transfer pricing anti-mismatch rules as set forth in articles 8ba to 8bd and 35 CITA end unilateral downward transfer pricing adjustments (i.e., in situations where...