06 January 2016

The Netherlands passes bill on supplementary transfer pricing documentation requirements in line with BEPS Action 13

The Dutch Parliament formally approved the Other Fiscal Measures Bill on December 22, 2015, which includes supplementary transfer pricing documentation requirements in line with the three-tiered approach of Action 13 of the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project. In addition, 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 December 30, 2015 (Ministerial Regulation). The supplementary transfer pricing documentation requirements are applicable for qualifying multinational enterprises for fiscal years starting on or after January 1, 2016.

A Tax Alert prepared by Ernst & Young Netherlands, and attached below, provides additional details.

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ATTACHMENT

Document ID: 2016-0016