Income Tax Compliance File – Information Requirements
Scope and Positioning
For the preparation of a Dutch income tax return (inkomstenbelasting), Nexpat maintains a structured client file in line with Dutch tax law, EU AML legislation and professional standards applicable to regulated tax advisors.
The file consists of:
- A permanent file
- A tax year-specific return file
- An advisory file
This structure ensures continuity, auditability and compliance, particularly in cases involving expat tax Netherlands matters, cross-border income streams and complex Netherlands tax structures.
1. Permanent File
1.1 Personal Identification and Civil Status
This section documents the taxpayer’s legal identity and household position for Dutch income tax purposes.
Required information:
- Full legal name and residential address
- Gender
- Date of birth
- Citizen Service Number (BSN)
- Marital or partnership status (single, married, registered partnership, cohabiting, divorced)
- Telephone number
- Email address
- Details of children: names or initials, dates of birth and BSN
Civil status directly impacts the application of fiscal partnership rules, allocation of income and deductions, and access to tax credits and allowances.
1.2 Identification and AML Documentation (Wwft)
In accordance with the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft), we are required to maintain identification and risk documentation.
Required documents:
- Copy of passport or EU identity card
- Wwft identification record
- Wwft risk profile
Where applicable:
- Prenuptial or partnership agreement
- Cohabitation agreement
- Will
- Donation deeds
- Employment contract
For expats and internationally mobile individuals, these documents are essential to assess cross-border asset ownership, inheritance exposure and potential anti-abuse implications.
1.3 Real Estate
For Dutch income tax purposes, real estate may fall under Box 1 (main residence) or Box 3 (investment property).
Required documentation:
- Purchase and sale deeds
- Notarial deed of transfer (title deed)
- Extract from the land register
- Mortgage or credit agreements
- Lease agreements (if rented out)
For cross-border structures, foreign real estate must also be documented, including local tax treatment and treaty allocation under applicable double tax treaties.
1.4 Movable Property and Financing
Where relevant:
- Ownership documentation
- Credit or financing agreements
- Lease or rental contracts
This may include assets relevant for Box 3 wealth taxation or business-related assets in case of self-employed individuals.
1.5 Loans and Credit Facilities
To assess deductibility and wealth position:
- Current account agreements
- Mortgage agreements
- Other credit agreements
Particular attention is required for shareholder loans, intra-group loans and cross-border financing arrangements.
1.6 Pension and Annuity Arrangements
Dutch income tax treatment of pension and annuity products depends on qualification criteria.
Required documentation:
- Annuity agreements or policies
- Existing rights agreements (stamrecht)
- Pension letters or pension agreements
- Endowment insurance policies
- Life insurance policies
For expats, it is critical to assess whether foreign pension rights qualify for Dutch tax deferral or fall into Box 3.
2. Tax Return File (Year-Specific Documentation)
2.1 Box 1 – Income from Work and Home
Employment Income
- Annual wage statement (jaaropgave)
- Information regarding company car
- Mileage administration
- Declaration of no private use of company car
- Social security benefits (WW, WAO, WIA, Wajong, Waz)
- Pension benefits
- Annuity payments
For expat tax Netherlands cases, we assess eligibility for the 30 percent ruling and the impact of partial non-resident taxation (where applicable).
Income from Other Activities
- Revenue statements
- Cost overview
This category includes “result from other activities” (resultaat uit overige werkzaamheden), which requires careful qualification analysis to avoid reclassification risks.
Other Income
- Alimony received
- Other periodic payments and entitlements
Cross-border alimony may trigger treaty considerations.
Main Residence (Eigen Woning)
- WOZ valuation decision
- Annual mortgage interest statement
- Mortgage balance as at 31 December
- Capital insurance linked to mortgage
- Savings or investment accounts linked to the home
- Purchase or sale documentation
- Renovation loans and additional borrowings
- Repayment status and amortisation compliance
Mortgage interest deductibility is subject to strict amortisation requirements and anti-abuse provisions.
Personal Deductions
- Medical expenses
- Education expenses (if still applicable under current law)
- Alimony paid
- Annuity premiums
- Charitable donations
Deductibility is assessed in light of current statutory thresholds and limitations.
2.2 Box 2 – Substantial Interest (Aanmerkelijk Belang)
Applicable where the taxpayer directly or indirectly holds at least 5 percent of shares in a company, including a holding company Netherlands structure.
Required documentation:
- Shareholding structure
- Dividend distributions
- Share disposals
- Acquisition cost
- Financing arrangements
- Meesleepregeling (asset inclusion rule)
- Meetrekregeling (attribution rule)
Cross-border shareholdings require analysis of treaty allocation, exit taxation and anti-abuse provisions under EU law.
2.3 Box 3 – Savings and Investments
Dutch wealth taxation applies to net assets as at 1 January of the tax year.
Required specifications (as at 1 January and 31 December, where relevant for substantiation):
- Bank and savings accounts
- Securities portfolios
- Investment real estate
- Annuity and endowment policies not qualifying for Box 1
- Debts
- Receivables
Recent jurisprudence and transitional legislation following the Supreme Court rulings on Box 3 require careful calculation based on actual returns or applicable transitional regimes.
Foreign assets must be fully disclosed.
2.4 Tax Assessments and Correspondence
To ensure procedural control and risk management, we require:
- Provisional assessments (reference, date, amendment requests)
- Final assessments (reference, date, objection status and decision date)
- Filed income tax returns
- Information on allowances (healthcare, rent, childcare, child-related budget)
- Correspondence with the Dutch Tax Authorities
- Objection filings
- Appeal proceedings
This is particularly relevant in cases involving international mobility, expat tax Netherlands matters and dual residency issues.
3. Advisory File
The advisory file documents the technical analysis and communication process.
It includes:
- Written correspondence with the client
- Written tax advice
- Internal memoranda
- Telephone notes
For internationally mobile individuals and entrepreneurs operating within a Netherlands tax structure, the advisory file typically addresses:
- Residency determination
- Treaty application
- Double taxation relief
- Substantial interest structuring
- Interaction with Dutch corporate tax in case of a holding company Netherlands
- Anti-abuse and substance considerations
Compliance and Professional Standards
Nexpat maintains client files in accordance with:
- Dutch income tax legislation
- EU AML requirements
- Professional standards applicable to regulated tax advisors
- Data protection requirements under the GDPR
Our engagement is focused on technically complex cases, including expats, international entrepreneurs and cross-border structures requiring precise and defensible tax reporting.