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.
The new decree clarifies the transfer pricing rules in the Netherlands with respect to:
• Intra-group services;
• Combating non-business motivated profit shifting;
• Guarantees; and
• Financing transactions including non-business motivated loans.
