On 11 May, the Dutch Ministry of Finance published its new Transfer Pricing Decree. The Decree provides further guidance on application of the arm's length principle and aims to incorporate recent changes following the OECD BEPS project and related changes in the 2017 OECD Transfer Pricing Guidelines. This Decree replaces the Decree of 14 November 2013.
The new Decree reflects a trend toward providing more detailed guidance on complex transfer pricing issues. The Decree emphasises the importance of conduct over contract and functions to control risks, as well as explicitly calling attention to penalties.
Read our analysis in our Insights article from Transfer Pricing