Dutch Tax Authorities Publish Mutual Agreement Procedures Report

Multinationals increasingly find themselves in tax disputes — not only with just one tax authority, but more and more often with tax authorities in several countries. Multinationals frequently have many different (intercompany) transactions, agreements, and contracts among themselves. Although multinationals want to avoid double taxation, when a tax inspector in one country makes a correction to the price for a product or service, the tax inspector in the other country often does not follow this exact correction, and the taxpayer ultimately pays tax on the same profit in two countries.

Transfer pricing cases mainly concern the allocation of profits between ...