The Dutch Court of Appeal Rules on Fundamental Transfer Pricing Questions Regarding a Business Reorganization

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This article describes an Amsterdam Court of Appeal Court Case of 11 July 2024 concerning transfer pricing, with regards to a business reorganization. The case highlights the necessity for taxpayers to meticulously document all aspects of a reorganization, ensuring alignment with the OECD Guidelines and proactively addressing potential valuation disputes. This ruling serves as a pivotal reminder for multinational enterprises to prepare robust transfer pricing analyses to withstand scrutiny and avoid adverse tax adjustments.