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As you may be aware, the Dutch Tax Authorities have recently launched new transfer pricing documentation requirements in line with the “3 tiered approach” as recommended by the OECD BEPS Action 13. The new transfer pricing documentation requirements are applicable for all fiscal years starting on or after January 1, 2016. This implies that your company needs to have the master file and/or local file readily available the moment you file the company’s 2016 corporate income tax return.
Dutch entities which are subject to the CbC reporting obligations should nevertheless before the end of the fiscal book year notify the Dutch tax authorities which entity within the group will file the CbC-report. Consequently for book years starting January 1, 2016 the deadline is December 31, 2016, however because of the new rules this has been extended to September 1, 2017!
In view of the above, you may wonder whether you could answer the following questions:
In order to help you answer the above questions and address any other transfer pricing subjects, please contact your MTH client manager or tax advisor.
So we could assist you in determining the best way forward and offer you a wide variety of support solutions. Such solutions would range from a so-called ‘gap’ analysis in which we compare your existing documentation with the new documentation requirements to offering a full transfer pricing documentation project.
Apart from the above we could also offer a number of solutions that allow you to undertake most of the work in-house, whereby you could request for our services on an as needed basis. In this context we could provide you with template reports to get started. We from our side would be available for you in case you would require support in areas like, talking to a sparring partner, provision of input on / execution of particular parts of the reports, review of work conducted by you or performance of benchmark studies.
For your information we attached here our memo on the new transfer pricing documentation requirements.