New Dutch transfer pricing documentation requirements previous message

New Dutch transfer pricing documentation requirements

The Dutch government has introduced new and more extensive Dutch transfer pricing documentation requirements as per January 1, 2016. The new legislation will probably require many companies to review and update their existing transfer pricing documentation framework. The main change with the past is that tax payers are required to disclose very specific and pre-defined topics in their documentation. Not complying with these rules will result in penalties and in worse case, imprisonment (4 years max.).

When relevant

The new legislation has been introduced this year and will be relevant in the following situations:

  1. The Dutch entity or branch is part of a multinational group with a (global) consolidated annual turnover of € 50 million; or
  2. Dutch entities/branches heading an international group or are part of  multinational group with a (global) consolidated turnover of at least € 750 million

What will change

In the following table we have included the main documentation requirements if you have business operations in the Netherlands.

new-dutch-transfer-princing-doc-requirements.jpg

Way forward

For more background information how to deal with this new legislation, please check our powerpoint presentation.

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