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Tax Alert: More Dutch Transfer Pricing requirements proposed

Sep 22, 2015

The Dutch Ministry of Finance announced a proposal for additional transfer pricing requirements in the Dutch Corporate Income Tax Act (Art. 29b – 29h CITA). A significant point is that for all book years starting January 1, 2016, Dutch entities that are part of a group with a consolidated turnover of at least EUR 50 million must include a master file and a local file in the administration of the Dutch group entity. This requirement accords with Action 13 of the OECD’s BEPS initiative.

The Dutch government estimates nearly 8,000 multinationals will have to draft transfer pricing documentation and more than 150 ‘Dutch’ ultimate parent entities will have to draft the additional country-by-country report.

To learn more details regarding the proposal, please refer to our alliance partner, Quantera Global’s blog

If you have any questions, please contact WTP’s National Transfer Pricing and Valuation Services Practice leader, Guy Sanschagrin at in the U.S. or the Dutch Quantera Global Team (Richard Slimmen, Theo Elshof, Rudolf Sinx and Olaf Smits) at +31 88 221 58 00 or

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