APA and ATR

APA and ATR

In many cases it is advisable to obtain upfront approval of the Dutch tax authorities regarding the tax consequences of a contemplated investment. This depends on e.g. the investment made, interests involved or level of comfort the company requires with respect to a certain transaction. This is usually achieved through a so called Advanced Pricing Agreement (in case of e.g. intercompany financing/pricing) or an Advanced Tax Ruling (for other specific situations). We have long and in-depth experience in preparing and mediation discussing such agreements with the Dutch tax authorities.