DTA TP Working Group Clarifies Approach To Transfer Pricing Risk Analysis

The Transfer Pricing (TP) coordination group of the Dutch Tax Authorities (DTA) recently published an internal note, Opzet en aandachtspunten TP‑analyse, explaining how inspectors are expected to prepare and structure transfer pricing risk assessments. Although non‑binding, the note gives taxpayers meaningful visibility into how cases will be reviewed and how the DTA performs early assessments to decide whether a full audit should be undertaken. Inspectors are instructed to start by forming a comprehensive understanding of the business - including group structure, key intercompany transactions, and multi‑year financial performance - before setting the scope and depth of further scrutiny.