From the USA

Transfer Pricing Between Your US and Dutch Companies: The Basics

Updated: 18 August 2026 USA Transfer pricing 2026

The moment your US and Dutch companies invoice each other, one rule governs: price as if they were strangers — the arm’s-length standard. For founder-led groups this is refreshingly manageable: three common flows, one pricing habit, and a slim file that keeps both tax authorities satisfied.

The three flows in a founder group

Services: the Dutch BV develops or supports for the US parent (or the reverse). Standard pricing: cost plus a modest markup, settled quarterly.
License: one entity owns IP the other uses. Standard pricing: a royalty in line with what independents pay for comparable rights — and if the IP should simply move, do it early: IP to the Dutch BV.
Goods: resale or manufacturing margins benchmarked against comparable distributors or makers: relevant for the import route: US webshops entering Europe.

The paperwork, right-sized

Founder-scale groups need a written intercompany agreement per flow and a short memo showing how the price was set — comparables or a cost base plus markup. Larger groups add the formal master-file and local-file documentation once revenue crosses the statutory thresholds. Both countries apply the same arm’s-length principle, so one honest analysis serves two files: how the standard stack divides work.

The habits that keep audits short

Invoice on schedule rather than at year-end; settle intercompany balances instead of letting them grow into disguised loans; refresh the pricing memo when the business changes shape. Auditors on both sides read consistency as competence — and move on.

Advice, free of obligation

Would you like our team to take a look at your situation?

Tell us where you stand or what you’re planning. Our team replies with advice, free of any obligation.

Part of Doing Business in the Netherlands — the complete 2026 guide.

Frequently Asked Questions

What markup is normal on intercompany services? +

Routine support and development services commonly price at cost plus 5–10%; higher-value functions earn more. The memo explaining your choice matters as much as the number.

Can I skip transfer pricing while both companies are mine? +

Common ownership is exactly why the rules exist: each country protects its share of the profit. A one-page agreement and quarterly invoices cost an hour and remove the discussion entirely.

Who checks this in practice? +

Both tax authorities can ask during a regular audit; the Dutch side may also look at it when losses or royalties move across the border. A current agreement plus the pricing memo answers the request by return mail.

Sources Belastingdienst · KVK · wetten.overheid.nl Last updated: 18 August 2026