The Newly Updated Dutch Transfer Pricing Guidance, Part 4: Intra-Group Services

On July 1, 2022, a new Dutch Transfer Pricing Decree No. 2022-0000139020 dated June 14, 2022 (hereinafter “new TP Decree”), was published in the Dutch Official Gazette. While the new TP Decree's most material change or update is the inclusion of extensive guidance on transfer pricing for financial transactions, it also in detail reiterates applicable rules for intra-group services. In particular it addresses shareholder services, low-value-adding services, contract research, and contract manufacturing as well as cost sharing and procurement services. For transfer pricing purposes, the main inq... Mehr ...