Transfer Pricing 2026

NETHERLANDS Law and Practice Contributed by: Jimmie van der Zwaan, Rob Langeveldt, Vasisthà Parmessar and Willem Koeleman, Borgen Tax

Borgen Tax is an Amsterdam-based independent ad - visory firm offering a full range of tax advisory and compliance services (including VAT, wage tax, M&A, international and European tax law, corporate income tax, real estate, and transfer pricing). Its focus is on tax disputes and transactions, nationally and inter - nationally. The firm consists of over 25 seasoned tax professionals and is part of Taxand Global, a network with tax law firms in nearly 50 countries. This allows it

to offer high-quality and integrated tax advice world - wide. The transfer pricing team at Borgen Tax helps clients to prepare and maintain appropriate transfer pricing documentation, including benchmark studies. The team also assists clients with business restruc - turings, (bilateral) advance pricing agreements with the tax authorities, and transfer pricing audits or dis - putes.

Authors

Jimmie van der Zwaan is a partner of Borgen Tax. He specialises in international corporate tax and transfer pricing. He frequently works on complex business restructurings and advance pricing agreement

Vasisthà Parmessar advises companies across various industries including consumer, energy, industrial and technology. His experience encompasses a wide array of transfer pricing matters, including the

negotiations. Jimmie is a member of the global Taxand transfer pricing service line, the Dutch Association of Tax Advisers and the Dutch Bar Association. Jimmie is also part of the team that co-ordinates the transfer pricing programme for the Dutch Association of Tax Advisers.

development of business and transfer pricing models, corporate restructuring, financial transactions, resolution of tax controversies, rulings, and value chain analysis. Vasisthà holds a dual degree, which includes a BSc in economics and business economics, an LLB in tax law, an LLM in tax law, and an MSc in accounting and auditing.

Rob Langeveldt is a partner of Borgen Tax. He specialises in international corporate tax and transfer pricing. Rob has over 16 years’ experience in developing and incorporating business and transfer

Willem Koeleman provides transfer pricing advice at Borgen Tax to companies across a range of industries, with a particular focus on financial transactions, including intercompany loans and guarantees.

pricing models, restructurings as well as negotiating the necessary multilateral, bilateral and unilateral advance pricing agreements as well as other tax rulings. Rob has also been involved in large compliance projects covering CIT, VAT as well as TP compliance services. Rob has university degrees in corporate, civil and tax law and is a member of the Dutch Association of Tax Advisers.

He has nearly five years of professional experience in transfer pricing. Willem holds a Master’s degree in International and European Tax Law from the University of Amsterdam and is a member of the Dutch Association of Tax Advisers.

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