Executive summary
On 4 March 2021, the Dutch Government initiated an online public consultation regarding the application of the arm’s-length principle. In line with the initiatives of the Organisation for Economic Co-operation and Development (OECD) and the European Commission to combat international mismatches, the Netherlands intends to unilaterally address certain transfer pricing mismatches to avoid international double non-taxation. The new rules are designed to be applied mechanically and…