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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 that need to be met in order to conclude an ATR/APA.