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).
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.