The arm’s length standard is well understood in theory. Defending it in practice requires documentation that is specific, current, and fit for scrutiny.

Transfer pricing is the body of rules that governs how transactions between related parties within a multinational group are priced for tax purposes. Dutch law incorporates the OECD arm’s length standard in Article 8b of the Wet op de vennootschapsbelasting 1969. Groups are required to maintain documentation — a master file and a local file — for each financial year in which they exceed the statutory thresholds. The Belastingdienst has significantly intensified its transfer pricing examination activity in recent years, and the threshold for triggering a formal inquiry has lowered. We assist groups at every stage: from policy design and documentation through to audit defence and advance pricing agreements.