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Netherlands Consulting on Draft Bills to Address Transfer Pricing Mismatches and Implement ATAD Reverse Hybrid Rules

|Proposed Changes|Netherlands
Netherlands

The Dutch Ministry of Finance has announced the launch of a public consultation on a draft bill to address transfer pricing mismatches arising through different applications of the arm's length principle in different countries. In particular, a new Article 8ba would be added to the Corporate Income Tax Act 1969 that would disallow downward adjustments if the Dutch taxpayer cannot establish that a corresponding upward adjustment was included in the foreign related party's tax base by the othe…

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