Dutch APAs and ATRs dropped in 2009
June 22, 2010
Eduard Sporken and Neil Schaatsbergen provide background information on APAs/ATRs in the Netherlands and comment on the related statistics recently published by the Dutch tax authorities.
The current Dutch practice regarding advance pricing agreements (APAs) and advance tax rulings (ATRs) entered into force on April 1 2001, following the publication of an Advance Pricing Agreement Decree (IFZ 2001/292M) on March 30 2001. In the APA decree, the Dutch deputy minister of finance states that Dutch taxpayers can obtain advance certainty on specific transfer pricing methods (by concluding an APA) or on the Dutch tax consequences of an envisaged cross-border transaction, such as hybrid tax structures (by concluding an ATR), as well as on whether or not the Dutch Revenue recognises the existence of a particular permanent establishment in the Netherlands.
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