Netherlands Gazettes Decree Clarifying OECD Guidelines on Arm’s Length Principle, Transfer Pricing for Multinational Enterprises

The Dutch Official Gazette July 1 published Decree No. 2022-0000139020, clarifying the OECD guidelines on the arm’s length principle and transfer pricing for multinational enterprises (MNEs). The decree includes measures: 1) explaining the application of the arm’s length principle; 2) explaining transfer pricing methods and secondary adjustments under the OECD guidelines; 3) clarifying pricing methods for transfers of intangible fixed assets between MNEs in the same group; 4) clarifying the arm’s length principle on group services; 5) explaining contributions under a cost contribution arrangement (CCA); 6) clarifying the pricing method used for assessing group purchases; 7) explaining the arm’s length ...