Advance Pricing Agreement Belastingdienst

September 8, 2021

The interpretation of tax laws and regulations is always the same for taxpayers. It doesn`t matter if you make prior agreements in an APA or atR. The importance of a judgment is a certainty in advance. Whether we are of opinion in advance or after, the tax and customs administration always acts in accordance with the law and, for example, never makes extra-legislative agreements on rates or exemptions. An ABS provides the taxable person with a prior guarantee for the determination of a subcontracting remuneration or a method for determining a subcontracting remuneration for cross-border transactions (goods and services) between organisations and affiliated undertakings or between entities of the same organisation or company. This is done on the basis of the OECD Transfer Pricing Guidelines. Thanks to prior advice, we offer companies operating nationally and internationally (but also individuals and small entrepreneurs) the opportunity to ensure in advance the application of tax laws and regulations. We do this within the framework of laws and regulations, directives and case law. This way, you know what to expect in terms of taxation. An ATR provides a taxable person with certainty in advance of the tax impact of a proposed transaction or combination of transactions in an international context.

This is the application of Dutch tax laws and regulations in a given situation to a given organisation or company. Example: the applicability or inapplicability of the subsidiary`s exemption. Substantive discussions may be held with the tax and customs administration on the impact of laws and regulations on the facts and circumstances presented. International companies usually talk about judgments when we create security in advance. This way, you know in advance where you stand when it comes to taxation. The inspector stops the pre-consultation when it comes to a fiscal exploration of the borders or a "conflict of good faith". For example, if the inspector suspects involvement in money laundering, corruption, serious property crimes or terrorist financing. In this summary you can read if and on which parties we give prior certainty about the application of tax laws and regulations. Send a copy of your APA or ATR application: the interpretation of tax laws and rules is always the same for taxpayers. It doesn`t matter whether or not you make prior agreements with an APA or atR.

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