Dutch Local File obligations 

Preparing a Local File requires careful attention as missing key information can cause compliance or audit risks. Determining which intercompany transactions are material, properly documenting them and selecting the right benchmarking methods can be complex and time-consuming. Our Dutch tax experts provide guidance and support throughout the entire Transfer Pricing process to help you meet OECD standards.

Materiality challenges in a Local File

Determining which intercompany transactions are material and must be included in the Local File can be challenging. While in practice thresholds are sometimes used, materiality depends not only on transaction value, but also on the functions performed, risks assumed and the value contributed by the Dutch entity, making professional judgement essential.

What makes an intercompany transaction material?

Intercompany transactions are considered material when their nature, scale and the economic contribution of the Dutch entity are significant. Materiality is not determined by a single threshold. Transactions that appear modest in amount may still be material depending on the functions performed, assets used and risks borne by the entity (especially when they are mispriced or not priced at all).

Common examples of transactions that often trigger inclusion in a Local File include:

• Payments to or invoices from group companies for IT services, software licenses, marketing, HR platforms, legal or corporate services
• Cross-border staff assignments or shared employees
• Use of intellectual property, software, or technology, including ERP/CRM systems, patents, trademarks or R&D
• Internal financing or guarantees, such as loans, cash pooling, or headquarters guarantees
• Goods flows within the group, including purchases, sales, or shared warehousing
• Shared services or cost allocations for finance, HR, IT, or marketing
• Corporate projects or group initiatives, like branding, global events, leadership programs, or strategy support

Not sure whether you listed all intercompany transactions that could be material? Download the checklist for further guidance and additional potential trigger.

Our transfer pricing support

Our team can manage the entire process, from initial assessment to final documentation, supporting compliance and minimizing audit risk. Whether you require advice, partial support or a fully managed solution, we guide your Dutch entity through all aspects of its Transfer Pricing obligations. We offer a full spectrum of Transfer Pricing services, including:

• Setting up Transfer Pricing policies
• Determining the appropriate TP methods
• Documentation of intercompany transactions
• Review of cross-border staff and shared functions
• Implementation of Transfer Pricing policies and compliance checks
• Local File & Master File preparation
• Country-by-Country Reporting (notifications)
• Support during audits or tax authority inquiries