The Netherlands issues favorable Decree clarifying application of transfer pricing anti-mismatch rules for asset transfers to Dutch corporate taxpayer through contributions and distributions

24 January 2023|Tax Alerts, Legislation & Policy, National/Federal Taxation, Transfer Pricing|Netherlands

Effective as of 1 January 2022, legislation was implemented in the Dutch Corporate Income Tax Act 1969 (CITA) to end unilateral downward transfer pricing adjustments.
Specifically, article 8bd CITA was introduced, preventing double non-taxation due to a valuation difference between jurisdictions in situations involving certain capital transactions such as contributions or distributions.
On 24 January 2023, the Dutch State Secretary of Finance published a Decree clarifying the application and scope…

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