Dutch transfer pricing rules require entities within international groups to price internal transactions as if dealing with independent third parties, following the OECD's Arm's Length Principle. This prevents companies from artificially shifting profits to low-tax jurisdictions.

Documentation requirements scale with the group's global revenue. Groups under €50 million need general records, while those earning up to €750 million require standardized Master and Local Files.

Groups exceeding €750 million must additionally submit a Country-by-Country Report.

Documentation must be completed by the annual corporate tax return deadline; failing to do so shifts the burden of proof entirely onto the corporation during tax audits.

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