Transfer Pricing

Clarification of anti-transfer pricing mismatch rule in the case of capital contributions

On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.
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Inflation and its impact on your transfer pricing

In many industries, rising prices are leading to reduced margins. How does that impact transfer pricing? This question is especially relevant if your company’s transfer pricing model is based on guara ...
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CJEU annuls Commission decision on Luxembourg transfer pricing ruling

The decision of the Court of Justice of the European Union brings key clarifications with regard to the choice of a reference system in transfer pricing State aid reviews.
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Transfer Pricing

If your business is part of a multinational group and has operations in various countries, then transfer pricing immediately comes into play. Intra-group transactions must be compliant with an ever‑in ...
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2022 Decree on Profit Attribution to Permanent Establishments

The most important changes are the incorporation of the results of the OECD’s BEPS project and the source exemption that was introduced into the Corporate Income Tax Act 1969 in 2012.
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2022 Transfer Pricing Decree

The changes to the Decree are mainly a reaction to the changes made to the OECD guidelines in respect of financial transactions, intra-group services and recent OECD publications on the treatment of g ...
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