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
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. Groups are required to maintain transfer pricing documentation 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.
What we do?
- Transfer pricing policy design and implementation across a group
- Transfer pricing documentation to OECD and Dutch standards
- Benchmarking studies for intercompany services, management fees, IP licences, financial transactions, and distribution arrangements
- Country-by-country reporting preparation and filing
- Transfer pricing risk assessment and health checks
- Advance pricing agreements, including unilateral, bilateral and multilateral requests with the Dutch competent authority
- Transfer pricing audit support, covering strategy, documentation review and representation
- Value chain analysis and profit split method studies for complex intra-group arrangements
Who is it for?
- Multinational groups with Dutch entities engaged in intercompany transactions of any kind
- Companies with intercompany loans, service agreements, IP licences, or distribution arrangements
- Groups approaching the country-by-country reporting filing thresholds
- Businesses subject to a transfer pricing inquiry or audit by the Belastingdienst
- Groups establishing new intercompany arrangements who require documentation from the outset
Get in touch with our specialists
CONTACT US
Let's get in touch
At Taxboutiq, we provide expert tax advice and tailored support for businesses and individuals. Whether you have a question about our services, need guidance on a tax matter, or would like to schedule an introductory meeting, we are happy to assist.