Transfer Pricing 2026

NETHERLANDS Trends and Developments

Trends and Developments Contributed by: Dirk Brouwers, Wessel van Dijk, Erwin Boomsma and Rocio Martel RED Transfer Pricing

RED Transfer Pricing (RED) is an independent Dutch advisory firm specialising in transfer pricing services. Since its establishment in 2013, the firm has focused on delivering technically robust and pragmatic solu - tions to Dutch and foreign (listed and privately owned) multinational enterprises, scale-ups, and private eq - uity-backed groups across industries. The service of -

fering of RED includes: transfer pricing advice and documentation; dispute resolution and APA support; value chain analyses and business restructuring; economic analyses/benchmark studies; operational transfer pricing; permanent establishment profit al - location and substance advisory.

Authors

Dirk Brouwers is partner and co-founder of RED Transfer Pricing. His clients include listed companies, privately owned companies and investment funds across different industries. He specialises in financial

Erwin Boomsma is a senior manager at RED Transfer Pricing. His clients include start-ups, scale-ups, multinational groups and listed companies. His areas of expertise include TP model design, strategic

transactions, transfer pricing valuations and dispute resolution (TP audit support, MAP and arbitrage procedures). Dirk is a frequent author in international transfer pricing journals and a member of the Dutch Association of Tax Advisors (NOB).

planning and implementation support. Erwin specialises in intangibles and business restructurings and he is (co-)author of several articles published in international transfer pricing journals.

Wessel van Dijk is partner of RED Transfer Pricing. His clients include a wide range of privately owned and private equity backed businesses active in multiple industries. He specialises in transfer pricing policy

Rocio Martel is a manager at RED Transfer Pricing with extensive experience in the transfer pricing practice in Mexico and the Netherlands, through which she gained solid expertise in local transfer

design and business restructurings. Wessel is a frequent author in international transfer pricing journals and a member of the Dutch Association of Tax Advisors (NOB).

pricing rules and regulations as well as OECD TP guidance. Rocío has experience in designing and implementing transfer pricing policies for multinational groups in different industries such as fast-moving consumer goods, pharmaceuticals, tech-companies and the automotive sector. Additionally, she is skilled in building financial models and helping clients to implement transfer pricing adjustments.

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