Dutch report on international tax and transfer pricing

Clive Jie-A-Joen and Monique van Herksen analyse the Dutch Revenue Service’s 2020 annual report on international tax rulings which provides preliminary insight into experiences with advance pricing agreements (APAs), advance tax rulings (ATRs) and other international tax rulings in the first full year of the revised Dutch ruling practice, including experiences on the concept of "economic nexus".

An APA serves to provide advance certainty on the determination of an arm’s length remuneration or a method for determining an arm’s length remuneration for international controlled transactions and dealings. An ATR consists of an agreement with the Dutch Tax Authorities on the taxing rights and obligations resulting from the application of Dutch tax laws and regulations in a taxpayer-specific situation.

This article was first published in MNE Tax.