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Transfer Pricing

Article 8b, documentation and intra-group pricing that survives review.

14 PUBLICATIONS

Latest · Legal Advisory

We Are Being Audited in Two Countries at Once

There is a particular kind of pressure in a cross-border tax examination that a domestic one never produces: two authorities, in two countries, looking at the same transactions from…

Transfer Pricing

Our Auditor Has Flagged Our Intercompany Pricing: What Happens Now

Transfer Pricing

Advance Pricing Agreements and Rulings in the Netherlands: Buying Certainty Before the Audit

Transfer Pricing

Netherlands and Spain: Managing Transfer Pricing Across Two Authorities

Transfer Pricing

Transfer Pricing Between a Dutch BV and a Canary Islands ZEC Entity

Transfer Pricing

The First Year: Transfer Pricing for Groups That Have Just Set Up in the Netherlands

Transfer Pricing

The Dutch Mismatch Rules: The End of Informal Capital and Downward Adjustments

Transfer Pricing

What the Belastingdienst Looks For in a Transfer Pricing Review

Transfer Pricing

Royalties, IP and DEMPE: Who Really Owns Your Intangibles

Transfer Pricing

Intercompany Loans, Guarantees and Cash Pooling: Pricing Debt Inside a Dutch Group

Transfer Pricing

Management Fees and Service Recharges Between Group Companies

Transfer Pricing

Master File and Local File in the Netherlands: What the 50 Million Threshold Actually Requires

Transfer Pricing

Running Global Transfer Pricing From the Netherlands: One Framework, Every Jurisdiction

Transfer Pricing

Article 8b: The Dutch Transfer Pricing Obligation That Applies Below Every Threshold

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