Transfer Pricing 2026

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

The outcome of TP audits is confidential and will not be published. 16.2 Use of “Secret Comparables” In principle, the DTA does not use secret comparables to substantiate pricing adjustments. They may, how - ever, use secret comparables in their TP risk assess - ment if doing so is considered appropriate and nec - essary.

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