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    icon Category: Blogs

    Intercompany services; do you provide an easy route to Transfer Pricing corrections?

    Almost all groups are engaged in intercompany services to some extent. This could for example include administrative, commercial, financial, technical or head office services. In practice we often see that these intercompany services are insuffici...
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    The OECD BAPA Manual: focus on international alignment

    On September 13th 2022 the OECD Forum on Tax Administration’s Bilateral Advance Pricing Arrangement Manual (“the BAPA Manual”) was approved by the OECD Committee on Fiscal Affairs. The manual covers almost 100 pages and addresses many issues that ...
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    What’s new? – New Decree on Profit Allocation for Permanent Establishments

    The Netherlands recently published its new guidance on allocation of profits to a Permanent Establishment (“PE”). The existing guidelines for such profit allocation already showed that, next to the discussion on the existence of a PE the profit al...
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    The four key trends from the Dutch Transfer Pricing decree that will impact business

    On 1 July 2022, the Dutch State Secretary for Finance issued a new Transfer Pricing Decree (hereafter: “the Decree”). For those unfamiliar with the Decree: legislation in the Netherlands on Transfer Pricing is relatively limited and the OECD Trans...
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    Aligning your transfer pricing policy with Pillar Two –preparations and forecasts for 2022

    In our November 2021 blog on Pillar Two, we informed you about the key elements of Pillar Two, including the most important transfer pricing elements. In this blog, we share our view on how you can best prepare now that the introduction in FY 2024...
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