Netherlands: New Transfer Pricing Decree

The Dutch Ministry of Finance has published a new transfer pricing decree. The decree provides guidance on the application of the arm’s-length principle to multinationals with Dutch transfer pricing arrangements and is largely consistent with OECD guidelines.

The decree provides clarification on the:

• characterization of intercompany transactions within multinational groups
• application of transfer pricing methods
• pricing of intangible assets when valuation is uncertain and in respect of hard-to-value intangibles.