Dutch transfer pricing: 10 years of evolution & global harmonization Schedule a call

    What’s your question?


    What’s your name?


    What’s your company name?


    How can we reach you?


    Navigating the complex terrain of Dutch transfer pricing: a decade of evolution and global harmonization

    In this blog post, we take a closer look at the insights gathered from a recent webinar on Dutch transfer pricing, expertly hosted by Quantera Global. Focusing on the ins and outs of transfer pricing in the Netherlands. This session provided a deep dive into regional challenges, opportunities, and regulatory landscapes. We’ll be sharing key takeaways and expert analysis from Rudolf Sinx and Stefan Ubachs, offering valuable guidance for businesses navigating this complex field. 

    The landscape of transfer pricing in the Netherlands has undergone profound transformations over the past decade. These changes reflect the country’s commitment to aligning with global taxation standards while addressing its unique economic and regulatory needs. This deep dive explores these evolutions, focusing on the intricacies of Dutch transfer pricing regulations and their synchronization with international guidelines. 

    The evolution of Dutch transfer pricing legislation 

    Over the last ten years, the Dutch approach to transfer pricing has seen a series of pivotal developments. A key milestone was the introduction of new transfer pricing decrees, which serve as the cornerstone of the Netherlands’ transfer pricing framework. These decrees provide clarity on the application of the arm’s length principle, a fundamental concept in transfer pricing, which necessitates that intercompany transactions are priced as if they were between unrelated parties. 

    Influence of OECD guidelines on Dutch policies 

    The Netherlands’ transfer pricing regulations are heavily influenced by the OECD’s BEPS (Base Erosion and Profit Shifting) action plan. This global initiative aims to prevent multinational enterprises from exploiting gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. The Dutch tax authorities have aligned with these guidelines through the incorporation of extensive documentation requirements, including the Master File (providing an overview of the multinational’s global business operations and transfer pricing policies), Local File (detailing specific transactional information), and Country-by-Country Reporting (providing a breakdown of the multinational’s allocation of income, taxes, and business activities by jurisdiction). 

    The 2022 Dutch transfer pricing decree 

    A critical development in the Dutch transfer pricing regime is the 2022 decree, which further underscores the centrality of the OECD guidelines. This decree offers nuanced perspectives on intercompany financial transactions, such as loans and guarantees, highlighting the Dutch tax authorities’ increasing focus on the substance and risk control of these transactions. Notably, it emphasizes the need for entities involved in financial transactions to demonstrate substantial control over associated risks, a move reflecting a more stringent and detailed approach to transfer pricing assessments. 

    EU developments and international tax trends 

    The Dutch transfer pricing landscape is also shaped by broader trends in the EU and globally. For instance, the EU’s Anti-Tax Avoidance Directives and the growing emphasis on substance over form have significant implications for Dutch transfer pricing policies. Internationally, initiatives like the OECD’s Pillar Two, aimed at establishing a global minimum corporate tax rate, are poised to influence Dutch transfer pricing regulations and practices. 

    Looking ahead: challenges and opportunities 

    As the Dutch transfer pricing regime continues to evolve, businesses must navigate a landscape marked by increasing complexity and heightened scrutiny. The harmonization of Dutch policies with international standards presents both challenges and opportunities for multinational enterprises operating in the Netherlands. Staying abreast of these developments and understanding their implications will be crucial for ensuring compliance and optimizing tax strategies. 


    The transformation of Dutch transfer pricing over the past decade underscores the dynamic and interconnected nature of international taxation. As the Netherlands continues to adapt its policies in line with global trends and standards, it remains imperative for businesses to remain vigilant and proactive in adapting to these evolving tax landscapes. 

    If you are interested to watch the entire webinar, feel free to click here. 

    Want to receive the latest relevant Transfer Pricing updates?