The Dutch Parliament approved the Other Fiscal Measures Bill that includes supplementary transfer pricing documentation requirements in order with the three tiered approach of Action 13 of the OECD Base Erosion and Profit Shifting (BEPS) project, on 22 December 2015.
With the supplementary transfer pricing documentation requirements, codified in articles 29b-29h of the Dutch Corporate Income Tax Act 1969, The Netherlands implements the OECD’s three-tiered approach for transfer pricing documentation consisting of the CbC report, the master file, and the local file. As a result, qualifying multinational enterprises should satisfy the supplementary TP documentation requirements for fiscal years starting on or after 1 January 2016.
Additionally, a Ministerial Regulation providing further rules regarding the form and content of the country-by-country (CbC) report, master file and local file has been published in the Government Gazette on 30 December 2015.
