01/July/2022
NL Tax Alert: New TP and profit allocation decrees
Today, the Dutch government published updated decrees on Transfer Pricing (TP) and on the attribution of profits to a permanent establishment (PE).
The updated TP decree reflects the additional OECD guidance on financial transactions and provides more guidance for intercompany services.
The PE allocation decree has been updated, reflecting changes to article 7 OECD Model Tax Treaty and BEPS developments. The decree contains welcome clarifications, e.g. on the dependent agent PE.
Sources: https://lnkd.in/eYDTqFKe and https://lnkd.in/etxRAHNC