The Netherlands has been a hub for international business at least since the 17th century As a consequence, The Netherlands has one of the most extensive tax treaty networks in the EU.
To avoid double taxation and reduce withholding taxes on dividends, interests and royalties, The Netherlands has concluded tax treaties with more than 90 countries.
To promote international business, investors can obtain certainty in advance about their future tax position. The possibility of obtaining an Advance Tax Ruling or an Advance Pricing Agreement (in the case of transfer pricing) is one of the most attractive features of Dutch tax law.
An Advance Pricing Agreement provides certainty in advance on the fiscal acceptability of the price that is paid for the provision of goods or services, between a Dutch and a foreign group company.
An Advance Tax Ruling is an agreement on the tax characterization of international corporate structures, such as certainty in advance on the application of the participation exemption.
Other attractive features of the Dutch tax rules include:
In order to have access to the Dutch tax regime a company requires a residence in The Netherlands. The rules for tax residence are the subject of much international debate, but to effectively claim residence a company has to have substance, which means that at least most directors are resident in the Netherlands. Other indications are