Patrick Schrievers Mark de Vaan Since the introduction of BEPS Action 13, a lot of countries have implemented, or are implementing, new transfer pricing documentation obligations for multinational groups in their domestic law. Such obligations have also entered Dutch law and have effect from financial years beginning on or after January 1 2016. Dutch law, decrees and policy, covering country-by-country reporting (CbCR) and master and local filing, are in line with what was agreed by the OECD and G20. Based on these obligations, multinational companies with a consolidated group turnover of €750 million ($857 million) or more must file an annual CbC report. In addition, Dutch taxpayers that are part of a multinational group with a consolidated turnover of at least €50 million in the preceding year should prepare an OECD-style master and local file for transfer pricing and branch allocation documentation purposes.
July 11 2017