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The Netherlands issues new decree on profit attribution to permanent establishments

|Tax Alerts, Legislation & Policy, National/Federal Taxation, Transfer Pricing, OECD|Netherlands
Netherlands

  • The Decree reflects the changes as a result of the OECD BEPS project, including the Additional Guidance on the Attribution of Profits to Permanent Establishments issued by the OECD in 2018.

  • While the Decree does not significantly differ from its prior version, it provides helpful guidance and insights on the views of the Dutch Tax Administration with respect to the attribution of profits to PEs.

  • MNEs should consider reviewing their policies in light of the guidance in this Decree.

Executive summa…

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