Executive summary
On 1 July 2022, the Dutch State Secretary of Finance (Finance Secretary) published a new decree related to transfer pricing and the interpretation of the arm’s-length principle in the Netherlands (Decree). The Decree replaces the previous transfer pricing decree dated 11 May 2018 and reflects the most recent changes in the Organisation for Economic Co-operation and Development’s (OECD’s) Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD Guid…