Advance Tax Ruling (ATR)

A tax ruling with the Dutch Tax Authorities provides you in advance with clarity regarding various tax-related aspects of cross-border enterprising. A ruling provides you with certainties in advance and prevents discussions later on with the Dutch Tax Authorities. Such a ruling is not only reserved for large companies quoted on the stock exchange. It is also an interesting option for a family business or SME that operates internationally.

By concluding a tax ruling you can be certain about issues such as:

• whether the Dutch participation exemption applies;
• whether this concerns a permanent establishment in the Netherlands;
• whether this concerns a non-resident taxpayer with regard to corporate tax;
• how the Dutch Tax Authorities view the treaty application, take for example dividend withholding tax.

The request to conclude an advance tax ruling is done by a competent tax inspector. At the same time, a copy is sent to the APA/ATR team of the Dutch Tax Authorities in Rotterdam. The application specifies all the relevant facts about your company.

In principle, the tax authorities decide about your application within 8 weeks. In additional information is needed, the tax authorities will extend this period. An ATR is usually concluded for a period of 4 to 5 years.

Would you like to obtain clarity in advance on the tax aspects of international business with an Advance Tax Ruling?

accon■avm can supervise your entire path – from application to an advance tax ruling. Contact one of the specialists in international tax advice via international@acconavm.nl .