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.
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?
Basic documentation
How prices are set, for every related-party flow.
Master and local file
Every year, available with the tax return.
Interest cap
Of tax EBITDA, or EUR 1 million if higher.
Conditional withholding
On interest, royalties and dividends to low-tax affiliates.
Where Dutch inspectors look
| Flow | Dutch focus | Typical fix |
|---|---|---|
| Loans | Rate, terms, non-business loan doctrine | Benchmark, security, repayment schedule |
| Management fees | Real services, mark-up | Cost plus 5% for routine services |
| Royalties | DEMPE functions, conditional withholding | Substance at the IP owner |
| Financing via the Netherlands | Conduit rules for financial service entities | Equity and local substance, or no ruling |
| Downward adjustments | Refused if not taxed abroad since 2022 | Align with the other country |
Dutch transfer pricing audits rarely start with models. They start with the question: who in the Netherlands decided this?
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.
Detail grows with group revenue.
Master and local file every year.
Interest cap above EUR 1 million.
25.8% conditional withholding.
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.