Transfer Pricing
Country Summary
The Netherlands

This document discusses the Netherlands’ transfer pricing regulations and their alignment with the OECD Transfer Pricing Guidelines. Key points include the integration of OECD principles into Dutch law, the definition of related parties, transfer pricing documentation requirements, audit practices, and compliance with BEPS Action 13. The Netherlands follows the OECD’s guidance on various aspects of transfer pricing.


Netherlands Transfer Pricing Regulations

The Netherlands has incorporated OECD Transfer Pricing Guidelines into its legislation. The guidelines play a crucial role in shaping Dutch transfer pricing regulations.

Defining Related Parties

According to Dutch law, related parties are entities that share management, control, capital, or common control. This definition is used to assess relationships that may lead to non-arm’s length transactions.

Transfer Pricing Documentation

Dutch transfer pricing documentation follows the OECD’s three-tiered approach, consisting of master files, local files, and Country-by-Country Reports (CbCRs).

Audit Practices

Dutch tax authorities conduct transfer pricing audits to verify accounting accuracy. They examine factors such as disclosure of intercompany transactions and adherence to transfer pricing rules.

BEPS Action 13 Compliance

The Netherlands complies with the Base Erosion and Profit Shifting (BEPS) Action 13. It aims to prevent international double non-taxation by making downward adjustments in cases of non-arm’s length transactions.

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