Netherlands: Changes to international tax ruling practice
The Netherlands has published the final Decree on the new Dutch international tax ruling practice. Beginning on 1 July 2019, international rulings cannot be concluded if the following conditions are met:
- The decisive aim in requesting the ruling is to avoid Dutch or foreign tax
- The companies requesting the ruling are based in low tax jurisdictions with a (statutory) corporate income tax rate below 9%, or are on the European Union’s blacklist
- The company does not have sufficient economic nexus in the Netherlands
All international tax rulings will have a maximum term of five years, which can be extended to 10 years under exceptional circumstances.