What does this research mean for the field?

In the Netherlands, despite limited explicit domestic guidance, the application of the profit split method is largely shaped by the OECD Transfer Pricing Guidelines and fact-based case law assessing functions, risks, and burden of proof. Novelty: ClaimNovelty.SYNTHESIS. Consensus alignment: ConsensusAlignment.NEUTRAL.

What question did this study set out to answer?

To examine the domestic statutory framework, administrative practices, and judicial interpretation governing the profit split method in the Netherlands.

August 28, 2026International Transfer Pricing Journal

The Profit Split Method across Jurisdictions – Report on the Netherlands

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Authors

GKGijsD.van Koeveringe NRNatalie Reypens

Discussion

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Overview

Jurisdictional review reveals reliance on international guidelines and fact-based case law for profit split method application in the Netherlands, highlighting domestic statutory gaps.

Key Points

To examine the domestic statutory framework, administrative practices, and judicial interpretation governing the profit split method in the Netherlands.
Analyzed Dutch domestic tax legislation and administrative guidance concerning transfer pricing methodologies.
Evaluated domestic advance pricing agreement practice alongside judicial decisions regarding functions, risks, and burden of proof allocation.
Contextualized domestic applications against the international framework of the OECD Transfer Pricing Guidelines.
Dutch statutory law and official administrative tax guidance offer minimal explicit instruction on executing the profit split method.
Application of the method is primarily directed by the OECD Transfer Pricing Guidelines alongside court jurisprudence requiring rigorous, fact-based evaluations of economic functions, operational risks, and evidentiary burdens.

Cite This Study

Koeveringe et al. (2026) studied this question.

synapsesocial.com/papers/6a91466cd15324a1df3aa013 https://doi.org/10.59403/3stxrcq

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August 28, 2026International Transfer Pricing Journal

The Profit Split Method across Jurisdictions – Report on the Netherlands

View Full Paper

Ask AI

Bookmark

Authors

GKGijsD.van Koeveringe NRNatalie Reypens

Discussion

Member takes

Overview

Jurisdictional review reveals reliance on international guidelines and fact-based case law for profit split method application in the Netherlands, highlighting domestic statutory gaps.

Key Points

To examine the domestic statutory framework, administrative practices, and judicial interpretation governing the profit split method in the Netherlands.
Analyzed Dutch domestic tax legislation and administrative guidance concerning transfer pricing methodologies.
Evaluated domestic advance pricing agreement practice alongside judicial decisions regarding functions, risks, and burden of proof allocation.
Contextualized domestic applications against the international framework of the OECD Transfer Pricing Guidelines.
Dutch statutory law and official administrative tax guidance offer minimal explicit instruction on executing the profit split method.
Application of the method is primarily directed by the OECD Transfer Pricing Guidelines alongside court jurisprudence requiring rigorous, fact-based evaluations of economic functions, operational risks, and evidentiary burdens.

Cite This Study

Koeveringe et al. (2026) studied this question.

synapsesocial.com/papers/6a91466cd15324a1df3aa013 https://doi.org/10.59403/3stxrcq

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