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Do you need tax advice?
Our tax advisors will be only too glad to help you or your accountant, whether your company is established in the Netherlands or abroad. Get expert advice anywhere in the world on national and international taxation.
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 that need to be met in order to conclude an ATR/APA.