Netherlands Transfer Pricing Policy

Email: ams4ww@evershinecpa.com
The Engaging Manager from Headquarter
Ms. Anna Wang, Speak Dutch English, and Chinese.
skype: burlinna

TP-Q-10
What kinds of scenarios will be adopted TP policy? What is the relevance between DTA and TP policy?

TP-A-10
When the Netherlands Tax entity would like to pay out whatever business profits, Royalty, Technical Services fees, Interests, trading amount, etc., it will adopt DTA tax rate. Its judge criteria, please see the Netherlands Treaty Page.
But if want to verify the above-mentioned amount if reasonable, will adopt the Dutch TP Policy.

TP-Q-20:   
What are the scenarios in Netherlands, that a Wholly Foreign-Owned Entity (WFOE) is exempted from compliance of Transfer Pricing (TP) declaration and TP documentation?

TP-A-20:

Local and Master File –

Companies with consolidated turnover of less than 50 million euros.

Country-by-country (CbC) Report –

MNE’s consolidated turnover less than 750 million euros in the fiscal year preceding the year.

TP-Q-30:   
What are the scenarios in Netherlands, that a Wholly Foreign-Owned Entity (WFOE) is required to submit a TP declaration to the country’s tax bureau? What is the name of the TP declaration form?

TP-A-30:

No TP declaration required.

TP-Q-40:   
What are the scenarios in Netherlands, that a Wholly Foreign-Owned Entity (WFOE) is required to submit TP declaration and TP documentation to the country’s tax bureau? What is the name of the TP declaration form and TP documentation form?

TP-A-40:

Local and Master File –

Companies with consolidated turnover of 50 million euros or more.

Country-by-country (CbC) Report –

MNEs in Netherlands with annual consolidated group revenue equal to or exceeding 750 million Euros in the prior fiscal year.

Netherlands TRANSFER PRICING for professionals

Overview

Transfer pricing rules apply to cross-border intercompany transactions with affiliated parties.

For Dutch tax purposes, transactions between all affiliated parties should be conducted at arm’s length.

The transfer pricing rules impose an obligation to disclose intra-group transactions in the annual tax return and to provide supporting transfer pricing documentation with the submission of the tax return.

Related companies

According to Article 8b of the Dutch Corporate Tax Act 1969, a related party is defined as a company that directly or indirectly takes part in management, control or capital of the other, or if both companies are under common control, which provides the first entity with sufficient control to influence relationships that may give rise to non-arm’s-length arrangements.

Permissible Pricing method

*Comparable Uncontrolled price method (CUP)

*Resale price method (RPM)

*Cost-plus method (CPM)

*Profit split method (PSM)

*Transactional net margin method (TNMM)

Due dates and respective threshold:

In Netherlands, there are no specific TP returns nor mandatory reports to be prepared.

Please be aware of below Warning:

The above contents are digested by Evershine R&D and Education Center in December 2022.
Regulations might be changed as time goes forward and different scenarios will adopt different options.
Before choosing options, please contact us or consult with your trusted professionals in this area.

Contact Us

Amsterdam Evershine BPO Service Limited Corp.
Email: ams4ww@evershinecpa.com
The Engaging Manager from Headquarter
Ms. Anna Wang, Speak Dutch, English and Chinese.
skype: burlinna

or
For how to exchange data files between your Finance Accounting System and Evershine Cloud Accounting Information System, please send an email to HQ4ams@evershinecpa.com
Dale Chen, Principal Partner/CPA in Taiwan+China+UK will be accountable for your case.
LinkedIn address: Dale Chen

Additional Information

Evershine CPAs Firm Headquarters
6th Floor 378 Chang Chun Rd., Taipei City, Taiwan ROC
Partner Kerry Chen, USA Graduate School and a well-English speaker
Tel No.: +886-2-27170515 ext. 105
Mobile: +886-939357000
Email: kerrychen@evershinecpa.com
Skype: oklahomekerry

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(version: 2024/07)

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