Transfer Pricing 2025

NETHERLANDS TRENDS AND DEVELOPMENTS

Trends and Developments Contributed by: Jan-Willem Kunen, Natalie Reypens and Gijs van Koeveringe Loyens & Loeff

Loyens & Loeff is a leading firm in the Neth - erlands, Belgium, Luxembourg and Switzerland and the logical choice for a legal and tax partner when doing business in or from these markets. Clients can count on personal advice from any of the 1,000 advisers based in the firm’s offices in the Benelux region, Switzerland or in key fi - nancial centres around the world, and they can rely on a full-service practice, specific sector

experience and a thorough understanding of the market. The Loyens & Loeff transfer pricing team provides a hands-on and tailor-made ap - proach to transfer pricing. With a team of around 30 tax lawyers and economists, it provides inte - grated solutions on all relevant transfer pricing issues. Major services offered include advice on planning and strategy, dispute resolution, quan - titative transfer pricing and documentation.

Authors

Jan-Willem Kunen is a senior associate and tax adviser at Loyens & Loeff who advises clients on Dutch and international transfer pricing and tax issues such as mutual

Natalie Reypens is a partner in the Amsterdam and Brussels office of Loyens & Loeff and heads the firm’s global transfer pricing team. She has 25 years’ experience in advising

agreement procedures, (bilateral) advance pricing agreements and OECD Pillar One and Pillar Two. Jan-Willem also has broad experience in advising on business restructurings, transfer pricing disputes, financing, IP, acquisitions and the setting up of international structures. He teaches transfer pricing courses at the Dutch Association of Tax Advisers. From 2014 to 2016, he worked at Loyens & Loeff’s Zurich office.

multinationals in international and corporate tax law. She assists multinationals formulating transfer pricing policies. She also advises on the setting up and conversion of business models, restructurings and profit allocation to permanent establishments. Natalie prepares and assists in preparing transfer pricing documentation. She also handles audits, rulings and APAs and disputes through MAP and arbitration. Natalie also has experience in EU state aid matters.

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