Transitional rules for 30% ruling also apply to adjustment with retroactive effect
Even if the 30% ruling is applied with retroactive effect in the payroll records in 2022 or 2023, employees will still fall under the transitional rules. This was announced by the Dutch tax authorities in its latest position.
Country by Country Reporting
Multinational entities with a consolidated turnover exceeding EUR 750 million are obliged to file an annual Country-by-Country (“CbC”) report. They must submit this to the Dutch tax authorities within 12 months of the end of the reporting year. Failure to comply with these Country-by-Country reporting requirements may result in significant administrative penalties.
Tax Audit
In a Tax Audit the tax authorities collect information in order to determine whether tax obligations have been complied with. The tax authorities can always question the taxpayer, either in writing or orally. They may also ask questions to third parties, for example the auditor. Tax Audit Assistance is advisable in case of a tax audit.
ATRs / APAs / BAPAs
Obtaining advance certainty on tax positions is a way to prevent disputes with tax authorities. Are you uncertain about tax positions or internal transactions between one or more of your company’s undertakings? Meijburg & Co has extensive experience in resolving such matters with the tax authorities.