The new Transfer Pricing Decree

October 6, 2022

08:30 - 12:30

The New Transfer Pricing Decree in the Netherlands

After two years of online events, we are delighted to invite you to our seminar “The new Transfer Pricing Decree”, to be held at our Amstelveen office on October 6, 2022.

We start with a plenary session, during which we will discuss with you and a representative of the Dutch Tax Authorities, Peter Klaver from the CGVP, the impact of the new Transfer Pricing Decree for businesses. This will be followed by a panel discussion with representatives from the business community.

This new transfer pricing Decree was published in the Netherlands on 1st July 2022.  The new Decree covers transfer pricing aspects of governmental subsidies, intra-group services and financial transactions including cash pools, guarantees, intra-group loans and financial service companies (“dienstverleningslichamen”). There are still many open questions about this Decree in practice.

The second part of the event will include four workshops to go in depth into some sections of the Decree and other recent transfer pricing developments.

Program

08:00    Breakfast
08:30    Intro
08.35    Plenary session
09.15    Panel with Q&A
10.00    Break
10.30    Workshops 1
11.30     Workshops 2
12.30    Lunch

Panelists:

  1. Jaap Reyneveld, Partner Transfer Pricing, Meijburg & Co
  2. Jos Druijf, representative from the Dutch Tax Authorities
  3. Ying Gu, Director, Transfer Pricing & Global Enterprise Model, SABIC
  4. Marc Kanter, International Tax and Global Transfer Pricing Head, AKZO NOBEL

Workshop A: Economic Analysis for Intercompany Loans under the New Rules: A Practical Perspective by Valentin Krustev (Director Transfer Pricing) & Lennaert Mosk (Senior Manager Transfer Pricing)
The new Dutch TP Decree introduces a number of concepts from Chapter X of the OECD Guidelines, as well as additional considerations for intercompany loans. Meijburg & Co’s financial transactions transfer pricing specialists will discuss what these new rules mean from a practical perspective when pricing loans, guarantees, captive insurances and cash pooling activities.

Workshop B: Finance Services Companies / DVLs and Substance in the new Transfer Pricing Decree by Fred van Horzen (Of Counsel General tax practice) & Janneke Versantvoort (Senior Manager Transfer Pricing)
Are DVLs still possible? When? How? This workshop will elaborate on the examples presented in the new Decree and explain the possible tax and WHT implications.

Workshop C: Considerations on Tax and Operational Transfer Pricing in relation to planned ERP implementation initiatives by Dianne Berry (Partner Transfer Pricing) & Quenton Martes (Senior Manager Business Analytics, KPMG Advisory practice)

How to leverage from finance transformations and ERP implementation initiatives to address Tax and OTP data challenges and integrate OTP into other finance and tax processes.

Workshop D: Global business trends that require you to review your transfer pricing by Jaap Reyneveld (Partner Transfer Pricing), Jeroen Kuppens (Director Transfer Pricing) & Eefje Lemmens (Director Transfer Pricing)

Possible impact of covid, work from anywhere policies, global supply chain disruptions, decentralization and new ESG requirement in your transfer pricing policies.

Language & PE hours

The working language of the seminar will be English.

Participation complies with the course requirements stipulated in the PE Regulations of the Dutch Association of Tax Advisors (Nederlandse Orde van Belastingadviseurs; NOB). 

 

Join us

We would like to invite you to join us for a light breakfast at our Amstelveen office prior to the seminar. Breakfast will be served between 8 a.m. and 8.30 a.m. There will be lunch served after the seminar, starting from 12.30 p.m.

 

One-on-one sessions

If you are interested in meeting one of our specialists before or after the seminar, our Transfer Pricing colleagues will be available for one-on-one sessions with you. Please confirm your interest by clicking here.

 

We look forward to welcoming you to our event!

 

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