Insights · Tax

Transfer pricing in the Netherlands for small and mid-sized groups

What Dutch transfer pricing rules mean for a B.V. with loans, fees or royalties inside the group: documentation by size, the interest cap, conditional withholding tax and the 2022 mismatch rule, with a check of your flows.
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Reading time5 minutes
TopicTransfer pricing
Rules as ofOctober 2026
AuthorAlexander Baranov
The short version

Every Dutch company documents its related-party pricing under article 8b; groups with EUR 50 million revenue or more prepare a master and local file every year, and EUR 750 million adds a country-by-country report. Net interest is deductible up to 24.5% of tax EBITDA or EUR 1 million. Interest, royalties and dividends to low-tax affiliates carry 25.8% conditional withholding tax, and since 2022 downward adjustments not taxed abroad are refused.

01 · The rule

Dutch transfer pricing for small and mid-sized groups

Article 8b of the Dutch corporate tax act requires arm's length prices between related companies, with documentation for every company. The level of detail grows with group revenue, but the questions in an audit are the same: is there an agreement, is the price defensible, and does the Dutch company do what the contracts say?

Every B.V.

Basic documentation

How prices are set, for every related-party flow.

EUR 50m+

Master and local file

Every year, available with the tax return.

24.5%

Interest cap

Of tax EBITDA, or EUR 1 million if higher.

25.8%

Conditional withholding

On interest, royalties and dividends to low-tax affiliates.

02 · Flows

Where Dutch inspectors look

FlowDutch focusTypical fix
LoansRate, terms, non-business loan doctrineBenchmark, security, repayment schedule
Management feesReal services, mark-upCost plus 5% for routine services
RoyaltiesDEMPE functions, conditional withholdingSubstance at the IP owner
Financing via the NetherlandsConduit rules for financial service entitiesEquity and local substance, or no ruling
Downward adjustmentsRefused if not taxed abroad since 2022Align with the other country
Dutch transfer pricing audits rarely start with models. They start with the question: who in the Netherlands decided this?
03 · Your case

Check your intra-group payments

Tick all flows that apply.

Check your intra-group payments in the Netherlands

Tick your flows and answer four questions. You get the documentation level and the risk points.

Which intra-group flows does the company have?
Written agreements and a pricing file?
Who is the counterparty?
Substance for financing or IP
Net interest expense a year
Need Dutch intra-group agreements and documentation?We draft the agreements and work with transfer pricing partners on benchmarks and master and local files, so your B.V. is ready for the tax office.
Get a quote
01Every B.V. documents

Detail grows with group revenue.

02EUR 50 million line

Master and local file every year.

0324.5% of EBITDA

Interest cap above EUR 1 million.

04Low-tax recipients

25.8% conditional withholding.

04 · FAQ

Transfer pricing in the Netherlands: frequent questions

What transfer pricing documentation does a Dutch company need?

Every Dutch company documents how its related-party prices are set. Groups with consolidated revenue of EUR 50 million or more prepare a master file and local file each year; above EUR 750 million a country-by-country report is added.

What is the Dutch earnings stripping rule in 2026?

Net interest expense is deductible up to 24.5% of tax EBITDA, or EUR 1 million if higher.

What is the Dutch conditional withholding tax?

A 25.8% withholding tax on interest, royalties and, since 2024, dividends paid to related companies in low-tax or EU-blacklisted jurisdictions.

Can a Dutch company take a downward transfer pricing adjustment?

Since 2022 not when the other country does not include the corresponding amount in its tax base, to prevent mismatches.

What happens without documentation?

The burden of proof shifts to the company, and administrative fines can apply.

Your structure

Need your Dutch intra-group pricing in order?

We draft intra-group agreements and coordinate benchmarks and master and local files with transfer pricing partners.