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What guidance is available regarding Dutch substance requirements?

Dutch case law is important to derive guidance regarding the place of effective management and control of a company. From case law it could be derived that it is important that the overall picture of the decision making process leads to the conclusion that the effective management and control of the company takes place in the Netherlands.

The Annex to the APA Decree (11th August 2004 IFZ2004/126M) contains a list of minimum substance requirements which need to be met in order to conclude an ATR/APA.

What guidance is available regarding Dutch substance requirements? - Duijn's Tax Solutions Contact us

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