The memorandum in response to the report provides answers to many questions, but there are still many points that need further elaboration, especially at the OECD level.
The new treaty will apply at the earliest from January 1, 2024 (but probably only from January 1, 2025). We have summarized some important aspects of the new treaty.
On January 24, 2023 Deputy Minister of Finance Mr. Van Rij clarified in a policy statement the scope of one of the measures to combat transfer pricing mismatches.
