The Evolution of the Dutch APA Practice – Analysis of APAs in the Netherlands

The advance pricing arrangement (APA) landscape in the Netherlands has changed since the 2019 APA decree became effective. The authors examine the developments in the Dutch APA practice, identifying the main trends, risks and opportunities for taxpayers. This article is based on both the information publicly available (e.g. APA summaries and annual reports published by the Dutch Tax and Customs Administration) and the practical experience of the authors in the field of APAs.