Executive summaryOn 1 July 2022, the Dutch State Secretary of Finance (Finance Secretary) published a new decree related to transfer pricing and the interpretation of the arm’s-length principle in the Netherlands (Decree). The Decree replaces the previous transfer pricing decree dated 11 May 2018 and reflects the most recent changes in the Organisation for Economic Co-operation and Development’s (OECD’s) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guidelines), most notably the inclusion of the guidance on financial transactions.1 The Decree also includes further details on the transfer pricing considerations with respect to governmental support, which have been particularly relevant...