In an effort to accommodate businesses, the Dutch Tax Authorities offer the option of making advance agreements with the tax inspector regarding specific transactions or structures. Such tax rulings offer businesses advance certainty on the Dutch tax treatment of a structure of transaction. These binding agreements with the Tax Authorities provide clarity on the application of certain fiscal rules in your specific situation. This helps prevent any differences in interpretation. Tax rulings are available to both major international corporations and Dutch small and medium sized businesses.
Two special types of rulings are available to foreign investors and international companies: Advance Pricing Agreements (APA) and Advance Tax Rulings (ATR). An APA offers certainty as to internal transfer prices, while an ATR offers certainty on aspects such as eligibility for participation exemption.
Fisconti has extensive experience when it comes to negotiating rulings on behalf of its clients. We will be glad to help you apply for and negotiate such agreements with the Tax Authorities. This includes both APA and ATR rulings as well as requests for advance rulings in other situations.