Advance Tax Clarity for Expats and International Investors

If you’re an expat planning to live, invest, or run a business in the Netherlands, navigating international tax rules can raise many questions. A Dutch Advance Tax Ruling (ATR) allows you to obtain official certainty from the Dutch tax authorities on how your specific situation will be taxed.

Whether you’re setting up a holding company, investing through the Netherlands, or dealing with hybrid structures, an ATR gives you confidence and clarity—before the tax year starts.

What Is an ATR?

An Advance Tax Ruling is a binding agreement with the Dutch tax authorities on how a certain tax rule will apply to your case. It is typically valid for four years and applies to cross-border structures and situations where the Dutch tax treatment is not entirely clear.

This can be especially useful for:

• Entrepreneurs expanding internationally;
• Foreign investors using the Netherlands as a gateway;
• Expats structuring global assets or activities via the Netherlands.

What Issues Can an ATR Cover?

An ATR can confirm the Dutch tax treatment of complex scenarios, including:

Participation Exemption

You can request advance confirmation that your Dutch company qualifies for the participation exemption, which allows tax-free repatriation of dividends and capital gains from foreign subsidiaries. This is particularly useful for intermediate and ultimate holding companies.

Hybrid Entities and Instruments

If you’re using hybrid financing instruments (e.g. convertible debt) or hybrid entities (e.g. LLCs or partnerships with different tax treatments abroad), the ATR can clarify how Dutch tax law will treat these structures.

Permanent Establishment (PE)

Are you running operations in the Netherlands through a foreign company? An ATR can confirm whether or not you have a Dutch permanent establishment, and what that means for your Dutch tax liability.

Requirements and Process

To be eligible for an ATR, your company must meet the Dutch substance standards and be structured for real economic activity, not just tax advantages.

The process usually includes:

• A pre-filing meeting with the Dutch tax authorities,
• A detailed ruling request backed by legal and financial analysis,
• A signed agreement confirming the tax treatment in advance.

Why Nexpat?

We support expats and international business owners in structuring their activities through the Netherlands with full tax certainty. Our team can help you assess whether an ATR is suitable, prepare the application, and represent you throughout the process.

Need tax clarity before expanding into the Netherlands?
Reach out to learn how an ATR can secure your international plans.