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The Netherlands issues favorable Decree clarifying application of transfer pricing anti-mismatch rules for asset transfers to Dutch corporate taxpayer through contributions and distributions

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Netherlands

  • Effective as of 1 January 2022, legislation was implemented in the Dutch Corporate Income Tax Act 1969 (CITA) to end unilateral downward transfer pricing adjustments.

  • Specifically, article 8bd CITA was introduced, preventing double non-taxation due to a valuation difference between jurisdictions in situations involving certain capital transactions such as contributions or distributions.

  • On 24 Januar…

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