Transfer pricing
Are you performing services or transactions to a related company?
Please be informed that the prices for these intercompany services and transactions should be at arm’s length. The at arm’s length price is the price that two unrelated parties would agree upon for the same transaction or service under the same or similar circumstances.
In the Netherlands every Dutch taxpayer is required to substantiate all intercompany pricing. The Dutch tax authorities can request such substantiation, including any underlying calculations of the at arm’s length price.
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As of 2016 additional documentation obligations in the form of a Master file and Local file apply to (multinational) groups exceeding the threshold of € 50 million consolidated group revenue in the year preceding the reporting year. If the consolidated group revenue exceeds € 750 million, the group is also obliged to prepare a Country-by-Country Report.
‘We are more than happy to have a look at all your intercompany transactions and services and see whether you’re compliant with the various transfer pricing rules and documentation obligations. We could also assist you in finding a suitable partner for composing a Master or Local File and/or perform a benchmark analysis.’
