We are happy to announce that we supported one of our clients in realizing the first APA of the Dutch Tax Authorities where the effects of Covid are agreed upon.
This APA confirms the transfer pricing policy as set for our client for the Covid-years 2020 and 2021. The agreed stable taxable results are fully aligned with the business and the arm’s length principle and adds true value to its cashflow and the overall tax position.
Looking back at the process we note a few remarkable elements:
– This was the first APA request filed and agreed upon. This is remarkable as MNEs do take positions about their transfer pricing policies under Covid-19 years 2020 and 2021. It is useful to know that an APA may be obtained on such (deviating) policies which can be very useful.
– The request was filed prior to the OECD’s report on this matter, and it proved solid.
– Our close and balanced cooperation with the Dutch Tax Authorities on achieving this result has proven key.
– It was very interesting to perform from a professional point of view, as there was no preconception of what to do (text borrowed from Giorgio Moroder).
Please send an e-mail to email@example.com if you wish to know more about the potential value of such an APA and/or the chances on obtaining one.