The TP rules apply to all Dutch taxpayers that are involved in cross-border intercompany transactions, including Dutch branches of foreign companies.The starting point of the arm’s length principle is that for tax purposes associated enterprises are assumed to act towards each other under the same conditions as independent companies would act under similar circumstances.The rules are not heavily formulaic but instead are principle-based. Furthermore, the transfer pricing regulations are based on the arm’s length principle as per Article 9 of the OECD Model Tax Convention on Income and Capital and nationally implemented in Article 8b of the Wet op de Vennootschapsbelasting 1969, ie it follows the OECD Transfer Pricing Guidelines (OECD TPG). The Dutch transfer pricing (TP) legislation is included in the Dutch transfer pricing decree no.2018/6865 (TP Decree) with additional documentation regulations implemented through the Dutch decree DB/2015/462M (Documentation Decree).Rather watch the transfer pricing videos? Please select a topic. ![]() More information about our services? Read more about our transfer pricing services. Our transfer pricing services include: governance, design & strategy, implementation, compliance, financial transactions and controversy. Quantera Global is an expert in transfer pricing.
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