New transfer pricing documentation rules for medium-sized multinationals previous message

New transfer pricing documentation rules for medium-sized multinationals

Also for multinationals with consolidated revenues of EUR 50 million or more the transfer documentation requirements are increased. Such multinationals must prepare a group file and a local file and have these files available for inspection in their accounting records.

The group file must include a description of the business of the multinational group, including the nature of its business operations, its complete transfer price policy as well as its worldwide allocation of income and economic activities. The local file must contain information relevant for the transfer pricing analysis regarding transactions between the Dutch company and affiliated entities other countries. Furthermore this local file must provide support for the profit allocation to the company’s foreign branches.

Both files must be prepared in the Dutch or English language and must be available ultimately at the moment that the corporate income tax return is filed.

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