Dutch Tax Rulings: 2023 Insights and Developments

This article delves into the 2023 key changes in Dutch tax rulings, analyzes the trends in ruling requests, and highlights the shift from unilateral to bilateral and multilateral Advance Pricing Agreements (APAs).

There is a (rather new) policy in the Netherlands which includes strict requirements for concluding international rulings by July 1, 2019. The policy sets out the parameters in which a Dutch ruling will not be able to be decided that includes the following:

• There is insufficient economic nexus (substance) in the Netherlands;
• The sole or decisive reason for the transaction is to save Dutch or foreign tax;
• The ...