21 May 2018

Dutch Finance Secretary publishes new Decree on application of arm's-length principle and OECD Guidelines

The Dutch State Secretary of Finance (the Finance Secretary) published a new transfer pricing Decree (the Decree) on May 11. The Decree contains a number of new sections and changes in light of the amendments to the Organisation for Economic Co-operation and Development's (OECD's) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017 (OECD Guidelines) as a result of the G20/OECD's Base Erosion and Profit Shifting (BEPS) plan and specific developments in Dutch case law.

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Document ID: 2018-1058