Transfer Pricing: Documentation is obligatory

stoplicht

The regulations are very clear: for all financial years as from 1 January 2016, Transfer Pricing Documentation must meet stricter Dutch and international criteria. In the Netherlands these criteria must be met at the latest when the period for filing the corporate income tax return expires.

Good planning is essential

While OECD based standards are in place, unfortunately, each country has its own deadlines. Good planning is therefore necessary in order to avoid penalties, and this means considerable effort is required. In the Netherlands, Transfer Pricing Documentation depends on the group revenues category into which your business falls. These group revenues are sub-divided into three categories, as set out below.

Meijburg & Co’s sound approach

Master Files, Local Files and Country-by-Country reports: these add a considerable burden to you documentation requirements. But how do you develop this documentation as efficiently as possible, and how do you then keep it up-to-date? We have developed a sound approach and technology for this. Our approach takes into account the Transfer Documentation available within your business. Meijburg & Co provides a variety of solutions, from complete documentation management to reviews, in order to identify potential risks, shortcomings and ‘dos and don’ts’. Our modular approach enables you to prepare some (potentially, a substantial part) of the documentation by yourself, either with or without the guidance of our specialists.

What are the conditions?

In the Netherlands, your Transfer Pricing Documentation obligations depend on the following:

  1. Group revenues of less than EUR 50 million
    Where consolidated group sales are less than EUR 50 million, general Transfer Pricing Documentation must be prepared.
     
  2. Group revenues of EUR 50 million or more
    Where consolidated group revenues are EUR 50 million or more, a statutory obligation exists to prepare a Master File and a Local File annually.
     
  3. Group revenues of EUR 750 million or more
    Where consolidated group revenues are EUR 750 million or more, a statutory obligation exists to prepare a Country-by-Country report annually, in addition to the Master File and a Local File.

tabel documentation

How Meijburg & Co can help

The additional Transfer Pricing Documentation requirements affect internationally-operating businesses with consolidated group revenues of at least EUR 50 million. This means a considerable increase in administrative burden in comparison with general Transfer Pricing Documentation requirements. In order to efficiently support you in this and to obtain a good idea of what the documentation requirements mean for your business, Meijburg & Co has developed a number of solutions.

Review

Meijburg & Co can assist you in determining the structure and content of the Master and Local Files pertaining to your business. In addition, we can review the Transfer Pricing Documentation you prepare, in order to identify potential risks, shortcomings and ‘dos and don’ts’.

Modular approach

In collaboration with you, we will assess which parts of the documentation you can prepare yourself, and which parts will be handled by Meijburg & Co. This integrated approach results in documentation, which combines your business know-how with our professional knowledge and experience.

Complete documentation management

Meijburg & Co takes responsibility for the entire project, ensuring that you meet all of your documentation requirements, and relieving you of all of your concerns.

Transfer Pricing Automated Documentation

Transfer Pricing Automated Documentation (TPAD) is a dynamic tool for preparing reports on the basis of data, information requests and templates. The request for information contains information specific to the local company. The template contains general information that applies to all specific companies.

Want more information about Transfer Pricing Documentation?

If you would like more information about Transfer Pricing Documentation, then Meijburg & Co would be pleased to discuss the matter with you. Please contact one of our specialists.

© 2020 Meijburg & Co, Tax & Legal, is a partnership of private limited companies, is registered in the Trade Register under number 53753348
and is affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.