At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: Belastingdienst (Netherlands Tax Administration). Summaries are simplified; check the linked official source before relying on them.
The law
#The arm's length principle is in Article 8b of the Corporate Income Tax Act 1969 (Wet Vpb 1969). Master file, local file and CbC rules are in Articles 29b to 29h Wet Vpb. The Netherlands follows the OECD Guidelines, as explained in the Transfer Pricing Decree 2022 (Verrekenprijsbesluit 2022).
Documentation
#All companies with related-party dealings must keep records in their administration showing how transfer prices were set and that they are arm's length (Art. 8b(3)). Group entities of a multinational group with consolidated group revenue of at least EUR 50m in the prior year must also add a master file and local file to their administration by the CIT return filing deadline (Art. 29g). The files are not filed with the return; they are provided when the tax inspector asks. They must be in Dutch or English.
Methods
#Taxpayers may choose any method that gives an arm's length result for the transaction (Transfer Pricing Decree 2022). OECD methods are accepted. Since 2022, a downward profit adjustment is denied if the other party does not include a matching upward adjustment in its profit tax (Art. 8bb).
Penalties
#Failing to file the CbC report or notification on time, through intent or gross negligence, can lead to an administrative fine up to the sixth-category amount under the Criminal Code (Art. 29h). If master file or local file are missing, the burden of proof can shift to the taxpayer. Normal reassessment penalties also apply.
Pillar Two
#The Netherlands' Wet minimumbelasting 2024 applies the IIR and a QDMTT from fiscal years starting on or after 31 December 2023 and the UTPR from 31 December 2024. Entities file the GIR (or a notification if it is filed abroad) 15 months after year end, 18 for the first year. The top-up tax return and payment come 2 months later: 17 months, or 20 for the first year.
Other rules
#APAs and advance tax rulings are available through the Belastingdienst APA/ATR team. Interest deduction is limited to the higher of 24.5% of adjusted profit (tax EBITDA) or EUR 1m (Art. 15b). Non-arm's length benefits can be treated as deemed dividends or capital contributions (secondary adjustments).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | CbC notification Must reach the Belastingdienst by the last day of the group's reporting year. It states whether the entity is the ultimate parent, surrogate parent or designated entity, or else names the reporting entity and its tax residence (Art. 29d). | Last day of the fiscal year (e.g. Dec 31, 2025) | Dutch group entities of a multinational group with consolidated revenue of at least EUR 750m. | Belastingdienst: Country-by-Country reporting |
| 2 | Corporate income tax return (aangifte vennootschapsbelasting) Due within 5 months after the fiscal year end (1 June for a calendar year). A company can ask for an extension, normally 5 more months (to 1 November for a calendar year). Under the tax advisor arrangement (beconregeling) the deadline can run to 1 May of the second year after a December year end, or the 16th month after year end for other years, if the advisor keeps to the filing schedule. | Extended: on request, 5 more months (e.g. Nov 2, 2026); original due date May 31, 2026 (moved from Oct 31, 2026, a Saturday) | All Dutch corporate income taxpayers. | Belastingdienst: Uitstel aangifte vennootschapsbelasting |
| 3 | Master file (groepsdossier) in the administration Must be in the company's administration within the period set for filing the CIT return for that year (Art. 29g). It is not sent with the return. It can be in Dutch or English. The filing period includes any extension granted for the return (for example to 1 November 2026). | With Corporate income tax return (aangifte vennootschapsbelasting) (extended) (e.g. Nov 2, 2026); original due date May 31, 2026 (moved from Oct 31, 2026, a Saturday) | Dutch group entities of a multinational group with consolidated group revenue of at least EUR 50m in the prior year. | Wet Vpb 1969, Article 29g |
| 4 | Local file (lokaal dossier) in the administration Must be in the administration by the CIT return filing deadline (Art. 29g). It can be in Dutch or English. Companies below EUR 50m have no fixed deadline but must be able to show how their prices were set when the inspector asks. The filing period includes any extension granted for the return (for example to 1 November 2026). | With Corporate income tax return (aangifte vennootschapsbelasting) (extended) (e.g. Nov 2, 2026); original due date May 31, 2026 (moved from Oct 31, 2026, a Saturday) | Dutch group entities of a multinational group with consolidated group revenue of at least EUR 50m in the prior year. All other companies still need basic TP records under Art. 8b(3). | Wet Vpb 1969, Article 29g |
| 5 | Country-by-country report (landenrapport) Filed within 12 months after the last day of the reporting year (Art. 29c). | 12 months after year end (e.g. Dec 31, 2026) | Dutch ultimate parent of a group with consolidated revenue of at least EUR 750m in the prior year, or a Dutch entity that must file locally. | Wet Vpb 1969, Article 29c |
| 6 | Bijheffing-informatieaangifte (GIR) or notification File the GIR via Digipoort 15 months after year end, 18 months for the first year (30 June 2026 for calendar 2024). If the GIR is filed abroad and exchanged, file a notification by the same date instead. Fines can reach the sixth category (over EUR 1m), but the Belastingdienst is holding back on late-filing fines for the first year. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | Belastingdienst: Bijheffing-informatieaangifte |
| 7 | Minimumbelasting return and payment Top-up tax return filed and paid 17 months after year end, 20 months for the first year (31 August 2026 for calendar 2024). No late-filing or late-payment fines through October 2026. IIR and QDMTT from fiscal years starting on or after 31 December 2023; UTPR from 31 December 2024. | 17 months after year end (e.g. May 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | Belastingdienst: Minimumbelasting aangifte doen en betalen |
Official texts
#- Wet op de vennootschapsbelasting 1969 (Articles 8b, 29b-29h) (No copyright on laws, decrees and regulations issued by public authorities (Auteurswet, Article 11))
- Verrekenprijsbesluit 2022 (Transfer Pricing Decree 2022) (Likely no copyright as a decree issued by a public authority (Auteurswet, Article 11); confirm)