Multinational groups are faced with questions such as:
- How to set up this documentation as efficiently as possible?
- How to keep the documentation up-to-date and consistent across the group?
- How to ensure it is prepared and filed on time.
In addition, benchmarking analyses to set and/or substantiate intercompany prices must be regularly updated. This includes benchmarking of financial transactions.
Transfer Pricing Documentation Solutions
Our team provides a variety of solutions. These solutions are fully adapted to your business needs. Our transfer pricing compliance services range from:
- Identifying potential risks and shortcomings during a documentation review engagement
- Only performing benchmarking analyses
- Complete documentation management where we relieve the in-house tax team
- Taking responsibility for meeting the group’s worldwide documentation requirements in a consistent manner.
Documentation requirements in the Netherlands and worldwide
The Netherlands
In the Netherlands, the Transfer Pricing Documentation required depends on the group’s consolidated revenue. That revenue will determine whether the following statutory requirements must be complied with:
- Preparing general transfer pricing documentation
- Preparing documentation in the Master File and Local File format and/or preparing and submitting a Country-by-Country report and/or notification.
Global Reach
Under the OECD’s BEPS Action 13, a standardized approach to transfer pricing documentation has been adopted worldwide. Many jurisdictions have implemented deadlines for preparing and submitting the Master File and Local File as well as for complying with Country-by-Country reporting obligations.
Some countries have additional local transfer pricing documentation or disclosure requirements that must be met. A sound process, including good planning and oversight, is necessary in order to meet compliance requirements and avoid penalties or other adverse consequences.
To get you started, there is the Global Transfer Pricing summary report prepared by KPMG Global Transfer Pricing Services. This regularly updated report lists the worldwide Country-by-Country reporting and Master File / Local File documentation requirements.
Our experts can help you plan and prepare your Transfer Pricing Documentation for the Netherlands and elsewhere. Depending on your needs, we work together with other transfer pricing specialists in KPMG’s Global Transfer Pricing Services network, thus ensuring compliance with local requirements.
Transfer Pricing Documentation Technology
- We use our own KPMG tax technology tools.
- We use tax technology tools developed by third parties.
- We assist you with add-ons for the tools your business uses.
Our tax technology approach is scalable and can be adjusted, depending on your needs and the size of your business.
We are able to supply tools for preparing transfer pricing documentation. We also supply a visual platform to help you with the documentation requirements and to monitor their status and keep track of deadlines. More information on transfer pricing technology can be found here.
How can Meijburg help you?
We will assess which part of the compliance process you would like to take care of yourself, and which part can be dealt with by our transfer pricing specialists. This integrated approach ensures compliant Transfer Pricing Documentation. The documentation combines your business know-how and market intelligence with our transfer pricing expertise and experience.
Questions? Feel free to contact one of our specialists.
Links & Downloads
FAQ
What istransfer pricing documentation?
Transfer pricing documentation includes detailed reports that multinational enterprises prepare to justify their intercompany transactions according to the arm's length principle. It consists of three components: the Master File, which provides a global overview of business activities and transfer pricing policies; the Local File, containing specific information about local intercompany transactions; and the Country-by-Country Report, offering insights into income, taxes, and economic activities per jurisdiction. This documentation is crucial for tax authorities to assess compliance with transfer pricing rules and to combat tax avoidance.
What level is transfer pricing documentation?
Transfer pricing documentation is structured into three levels: the Master File, Local File, and Country-by-Country Report. The Master File offers a global overview of a multinational's operations and transfer pricing policies. The Local File provides detailed information on intercompany transactions specific to a local entity, including transfer pricing methods and financial data. The Country-by-Country Report aggregates data on income allocation, taxes paid, and economic activity across jurisdictions. This three-tiered approach, as recommended by the OECD's BEPS Action Plan 13, aims to enhance transparency and ensure compliance with arm's length principles in transfer pricing practices.
What is the threshold for transfer pricing documentation in the Netherlands?
In the Netherlands, transfer pricing documentation requirements depend on the multinational enterprise's revenue. A Master File and Local File are mandatory for enterprises with consolidated group revenues of at least €50 million in the previous fiscal year. The Country-by-Country Report is required for those with revenues of €750 million or more. The ultimate parent company must file this report. These thresholds align with the OECD's BEPS Action Plan 13, promoting transparency and compliance in transfer pricing practices.
