Other than the Dutch Transfer Pricing Decrees 2001 and 2004 the Transfer Pricing Decree issued on14 November 2013 no. IFZ 2013/184 M refers only to transfer pricing issues of associated companies. It does not contain any tax policy clarifications regarding the allocation of profits to permanent establishments. The Secretary of State for Finance did not consider such information necessary as guidance on the allocation of profits to permanent establishments is provided in his Decree of 15 January 2011, IFZ 2010/457M. For several reasons a supplementary PE-Decree is recommended.
|Translated title of the contribution||Supplementary Decree Allocation of Profits to Permanent Establishments recommended|
|Number of pages||3|
|Journal||Nederlands Tijdschrift voor Fiscaal Recht|
|Publication status||Published - 23-Oct-2014|
- profit allocation