Reinout de Boer, Michael Molenaars, Rogier van der Struijk, Mieke Lavreysen and Tirza Cramwinckel contributed to the Tax Disputes and Litigation review in a chapter about the Netherlands.
The chapter provides a practical overview of common issues that give rise to tax disputes in the Netherlands, the procedures for resolving those disputes, and the powers and approach of the Dutch Tax Administration. The chapter offers insights into the process, timescale and cost of resolving complex difficulties in the Netherlands, with a focus on recent developments.
Traditionally, the Dutch Tax Administration has been willing to cooperate on mitigating uncertainty for taxpayers up front, especially by means of the Dutch ruling practice under which taxpayers can apply for advanced tax rulings and advance pricing agreements. In recent years the Dutch ruling practice has been revised; taxpayers nowadays need to meet stricter measures to obtain a Dutch international tax ruling, such as that the taxpayer needs to have sufficient ‘economic nexus’. When a tax controversy arises in the Netherlands, taxpayers generally experience a relatively open and approachable attitude from the Dutch Tax Administration. Taxpayers are likely to be confronted more frequently with tax audits and tax disputes as a result of the changing global tax atmosphere, especially concerning tax structures that are perceived as potentially aggressive tax planning.
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Authors: Reinout de Boer, Michael Molenaars, Rogier van der Struijk, Mieke Lavreysen and Tirza Cramwinckel
Source: the Tax Disputes and Litigation review – tenth edition
Publication date: February 2022