Master File for Dutch entities 

Multinational groups often assume that their global Master File is sufficient, but Dutch tax authorities may have specific requirements regarding the role, functions and risks of the Dutch entity. Even a well-prepared global Master File may require adjustments, as even small gaps can raise questions during a tax audit. Compliance is essential not only to avoid penalties but also to maintain defensible and transparent documentation. Our experts can review your global Master File, guide you on the necessary adjustments or help you build a fully compliant Dutch Master File from scratch.

Key components of a Dutch Master File

Even if you already have a global Master File, it often requires Dutch-specific adjustments to ensure full compliance, especially regarding the Dutch entity’s role in the group (this is especially true if the Dutch activities are small by comparison to the rest of the group). A Master File contains the following:

1. Organizational structure – charts of legal and ownership structures

2. Business description – main products and services, key value drivers, supply chain, functional analysis, geographic markets, and restructuring events

3. Intangibles – ownership, R&D strategy, licensing agreements, and transfer pricing policies

4. Intercompany financial activities – group financing arrangements, central treasury functions, and transfer pricing policies

5. Financial and tax positions – consolidated financial statements, unilateral APAs, and other relevant tax rulings

Does your Master File reflect your Dutch entity under OECD guidelines?

Even groups with an existing Master File often encounter challenges when operating in the Netherlands. Global documentation may be outdated, incomplete or inconsistent, while the Dutch entity’s functions, risks and intercompany transactions are sometimes insufficiently detailed. Collecting accurate information across multiple jurisdictions can be time-consuming and misalignment between the Master File, Local File and transfer pricing policy can increase audit exposure.

To help you get started, our Master File Checklist allows you to assess whether your existing documentation meets Dutch requirements and highlights areas that may need adjustment.

360° Transfer pricing support

We can help prepare both your Master File and Local File, as well as manage Country-by-Country reporting and notifications. Our specialists provide full-spectrum transfer pricing support, from a light compliance review to complete end-to-end management, tailored to your needs. We guide you through Dutch-specific requirements, align your documentation with OECD standards to make sure the role and activities of the Dutch entity are fully reflected.

Let us know how we can assist your organisation and we would be happy to discuss your situation in an introductory call.