DLA Piper Netherlands

Roderik Bouwman & Gabriël van Gelder of DLA Piper assess recent developments in Dutch tax law, including the legislative proposal concerning ATAD 2, a letter from the state secretary of finance on recent ECJ judgments and a new policy on a tax ruling relating to cross-border structures.

The Netherlands is renewing and revising its practice regarding advance tax rulings (ATRs) and advance pricing agreements (APAs). The Dutch government expects that these renewed Dutch ruling practice shall take effect July 1 2019.

The Dutch State Secretary of Finance sent a letter to the Dutch Parliament on February 26 2019, answering questions raised by members of the House of Representatives on the proposed changes to the Dutch tax ruling practice, and announced introduction of a conditional withholding tax (WHT) on intra-group, outbound interest and royalty payments.