Executive summary On 4 March 2021, the Dutch Government initiated an online public consultation regarding the application of the arm’s-length principle. In line with the initiatives of the Organisation for Economic Co-operation and Development (OECD) and the European Commission to combat international mismatches, the Netherlands intends to unilaterally address certain transfer pricing mismatches to avoid international double non-taxation. The new rules are designed to be applied mechanically and should take effect for fiscal years starting on or after 1 January 2022. If enacted, the new rules as included in the consultation document would impact Dutch corporate taxpayers involved in international...