• Service: Tax, Global Transfer Pricing Services, International Tax
  • Type: Regulatory update
  • Date: 12/16/2013

Netherlands - Analysis of new transfer pricing decree 

December 16:  The Dutch Deputy Minister of Finance in late November 2013 issued a decree that generally unifies and clarifies prior transfer pricing guidance, and withdraws and cancels prior decrees from 2001 and 2004.

The effective date for the new transfer pricing decree is 27 November 2013.

Multinationals with group companies and activities in the Netherlands, therefore, need to anticipate the application of the new policy under the decree.

A December 2013 report [PDF 141 KB] prepared by transfer pricing professionals with the KPMG member firm in the Netherlands examines the new decree with respect to:

  • Intra-group services
  • Combating non-business motivated profit shifting (in particular as it concerns (in)tangible fixed assets, central purchasing within the group and internal insurance/reinsurance activities)
  • Guarantees
  • Financing transactions including non-business motivated loans

A version of this article was published in Bloomberg BNA Transfer Pricing Report Vol. 22 No. 16 (12 December 2013), and is provided here with permission.

For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services practice:

Eduard Sporken

+31 (0)20 6561618

Jaap Reyneveld

+31 (0)20 6561114

Jeroen Dijkman

+31 (0)10 4536843

Or contact a tax professional with KPMG's Global Transfer Pricing Services.

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