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An in-depth analysis of published anonymized APA and APA request summaries under the revised Dutch tax ruling practice Koen Bolink

By: Bolink, Koen.
Material type: ArticleArticlePublisher: 2021Subject(s): ACUERDOS PREVIOS SOBRE PRECIOS DE TRANSFERENCIA | PRINCIPIO DE PLENA COMPETENCIA | PAISES BAJOS In: Intertax v. 49, n. 3, March 2021, p. 278-291Summary: On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations and to increase its openness and transparency. In this respect, the Dutch tax authorities now publish anonymized summaries of Advance Pricing Agreements (APA) and Advance Pricing Agreement requests. The article provides an in-depth analysis of all sixty-six anonymized summaries published during the first year after the introduction of the revised Dutch tax ruling practice and highlights and analyses the most significant cases. This provides further insight into the practical application of the requirements that taxpayers must fulfil to be eligible for prior consultation to obtain a tax ruling with an international character.
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Resumen.

On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations and to increase its openness and transparency. In this respect, the Dutch tax authorities now publish anonymized summaries of Advance Pricing Agreements (APA) and Advance Pricing Agreement requests. The article provides an in-depth analysis of all sixty-six anonymized summaries published during the first year after the introduction of the revised Dutch tax ruling practice and highlights and analyses the most significant cases. This provides further insight into the practical application of the requirements that taxpayers must fulfil to be eligible for prior consultation to obtain a tax ruling with an international character.

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