Assistance with transfer pricing
New Dutch tax law entered into force effective January 1, 2016 containing detailed transfer pricing documentation requirements in line with Action 13 of the OECD’s ‘Base Erosion and Profit Shifting’ (BEPS) initiatives.
These requirements include a country-by-country report, a master transfer pricing (TP) file, and a local TP file. Similar requirements apply in many other countries.
These TP documentation requirements apply if the consolidated revenue of the MNE Group of the preceding tax year is at least EUR 50 million. But even if revenues are less, certain TP documentation is required to sustain the appropriateness of cross border intercompany transactions.
The master file should provide a high-level overview of the MNE group’s global business structure and its TP policies. The local file is meant to supplement the master file and is intended to deliver a more detailed overview of the specific intra-group transactions that are entered into by the Dutch group entity and the reconciliation of the TP policies with the actual result.
“TP documentation requirements apply if the consolidated revenue of the MNE Group of the preceding tax year is at least EUR 50 million.”
“But even if revenues are less then EUR 50 million, TP documentation is required”
Our TP services include but are not limited to
- Determination whether TP filing is required
- Assisting in preparation of the appropriate TP documentation (master file, local file, other filing)
- Performing a tax risk analysis based on the TP analysis and filing
Would you like to learn more about the TP filing obligations, please feel free to contact us.
Other subjects that may be of interest:
- Advice on any Dutch corporate tax matter
- Advice about the fiscal unity regime
- Advice about optimizing debt finance