The importance of Transfer Pricing
With more international activity, your tax obligations toward various foreign governments will also be extended. Higher levels of cross-border transactions therefore require a more extensive - and consistent - registration in your records of the underlying transactions within your group. A good record of the internal transfer prices applicable within your enterprise is indispensable and a key component of your risk management. After all, a lack of good Transfer Pricing documentation may result in time-consuming and costly discussions with various tax authorities and/or in your profits being taxed double. Let us give you advice!Download
Rules in the Netherlands
At the end of 2015, additional legislation relating to Transfer Pricing came into force. This has major implications for international companies with one or more companies or permanent establishments abroad. From the 1st of January 2016 onwards, a distinction has been made on the basis of the consolidated group turnover with respect to the documentation requirements and defining group information. We refer to the document in the link below for more detailed information. However, Transfer Pricing is not only an issue in international situations. Under Dutch law, companies are also under a statutory obligation to document transactions between divisions conducted within the same country.
Baker Tilly Berk supports you in identifying the tax risks in your Transfer Pricing system, in minimising these risks and in spotting opportunities. This can be achieved in several ways:
- Optimisation of your business model for tax purposes
- Guidance of your organisation with respect to its legal obligations
- Guidance in concluding Advanced Pricing Agreements
- Support in discussions with the Dutch Tax Administration
Do you have questions about Transfer Pricing?
As a consultant to Small and Middle Market Enterprises, treated as corporate, Baker Tilly Berk is familiar with the operations of a wide spectrum of companies and is consequently ideally able to practically and efficiently identify the various business processes you rely on for your profits. In addition, the Baker International network offers excellent opportunities for you to have your Transfer Pricing documentation in different tax jurisdictions drawn up and/or assessed in a coordinated manner. Please contact us for more information.
In our unique app: the Tax Mapp, you will find both the latest worldwide tax news and complete current tax overviews per country. The Tax Mapp can be downloaded for free from the App store and the Google Play Store.
File your Country-by-Country report 2016 and notification for financial year 2017 before 31 December 2017
As of January 1, 2017 new Transfer Pricing documentation requirements are in place for Dutch entities who are part of an international group with a consolidated group revenue of at least 750 million euro.
Tax treaty changes with MLI
It is likely that over the coming years a large number of tax treaties will be changed. Possible changes to your future tax status.
Activities in the USA? Be aware of transfer pricing requirements
Prevent your company from incurring substantial IRS penalties for transfer pricing adjustments upon audit.