Dutch Tax Advisory and Compliance Services

Scope of Services

Nexpat advises international entrepreneurs, expats and corporate groups on Dutch corporate tax and cross-border tax structuring.

Our work combines technical advisory, procedural representation and ongoing tax compliance within a coherent Netherlands tax structure.

We focus on legally robust solutions aligned with Dutch tax law, EU directives and OECD standards.

Dutch Tax Advisory

Corporate Tax and Structuring

We advise on the design and implementation of Dutch corporate tax structures, including:

  • Establishment of a holding company Netherlands structure
  • Formation of subsidiary and intermediate holding companies
  • Corporate reorganisations and legal mergers
  • Share transfers and step-up planning
  • Financing structures and interest deductibility limitations

Advice includes analysis of the Dutch participation exemption, interest deduction rules, anti-hybrid provisions and conditional withholding tax on interest, royalties and dividends.

Substance, beneficial ownership and Principal Purpose Test considerations are addressed at structuring stage.

International and Cross-Border Tax

We advise on international tax aspects relevant to operating in or through the Netherlands, including:

  • Application of tax treaties and EU directives
  • Permanent establishment risk assessment
  • Cross-border management structures and place of effective management
  • Withholding tax exposure and treaty relief procedures

Structures are reviewed against Dutch anti-abuse provisions, ATAD implementation and evolving international standards.

Transfer Pricing and Tax Accounting

We assist with:

  • Transfer pricing analysis and documentation
  • Intra-group financing structures
  • Benchmarking studies
  • Dutch tax accounting positions
  • Deferred tax calculations in financial statements

Transfer pricing policies are aligned with OECD guidelines and Dutch documentation requirements.

Rulings and Advance Certainty

Where appropriate, we support applications for advance tax rulings with the Dutch tax authorities.

Ruling requests are prepared in line with current Dutch ruling practice, including substance requirements and transparency standards.

Dispute Resolution and Tax Audits

We represent clients in:

  • Objection and appeal procedures against Dutch tax assessments
  • Discussions during tax audits
  • Horizontal monitoring arrangements

Procedural strategy is developed with attention to evidentiary standards and litigation risk.

Tax Residency and International Mobility

We advise on:

  • Corporate tax residency analysis
  • Alignment of management and control with Dutch residence
  • Expat tax Netherlands considerations
  • Personal income tax residency planning
  • Interaction between corporate and personal tax positions

Dual residency risks and treaty tie-breaker implications are analysed in advance.

Voluntary Disclosure

We assist with voluntary disclosure of previously unreported income, including foreign income.

This includes analysis of penalty exposure, mitigation strategy and structured communication with the Dutch tax authorities.

Dutch Tax Compliance

In addition to advisory services, we provide structured tax compliance support.

Corporate and Personal Income Tax

  • Preparation and filing of Dutch corporate income tax returns
  • Preparation and filing of Dutch personal income tax returns
  • Review of preliminary and final assessments

Returns are prepared with attention to international elements, participation exemption, foreign tax credits and treaty positions.

Indirect and Withholding Taxes

  • Preparation and filing of VAT returns
  • Dividend withholding tax returns
  • Assistance with wage tax coordination in international settings

Compliance services are integrated with advisory work to ensure consistency and defensibility.

Dutch Tax System

For a technical overview of the Dutch corporate tax framework, the Netherlands tax structure and related regulatory environment, we refer to the section Dutch System in the main menu.

Engagement Approach

Our advisory work is designed for internationally active businesses and individuals who require technically precise and defensible tax solutions.

Initial discussions focus on identifying material risks, cross-border exposure and structuring objectives.

Engagements are structured clearly in terms of scope and responsibility.

For an assessment of your Dutch tax position or international structure, you may contact Nexpat to discuss the relevant facts and determine the appropriate next steps.