Netherlands: Transfer Pricing

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Article
Dutch Ministry Of Finance Updates Hybrid Mismatch Decree: Broader Guidance And New Practical Examples
The Dutch Ministry of Finance has issued an updated Decree providing crucial clarifications on the practical application of hybrid mismatch rules under ATAD2. These updates address key interpretative questions that have emerged in practice, particularly concerning the interaction with US tax regimes, capitalised acquisition costs, and cost-plus transfer pricing structures.
Netherlands Tax
LL
Loyens & Loeff
Article
OECD Consultation On Chapter VII (Intra-Group Services): Submitted Comments And Key Considerations
The OECD's proposed revisions to Chapter VII of the Transfer Pricing Guidelines represent the most extensive rewrite of intra-group services guidance in years, introducing new requirements for accurate delineation, expanded benefit testing, and dedicated documentation standards. Loyens & Loeff's Transfer Pricing team has submitted detailed comments assessing whether these changes reduce compliance burdens or risk increasing double taxation for multinational enterprises.
Netherlands Tax
LL
Loyens & Loeff
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