The Dutch government published its 2024 Annual Report on Tax Rulings on May 22, 2025. The document reveals relevant trends in Advance Pricing Agreements (APAs) and highlights the stability of the advance tax agreement system.
Number of APA applications remains steady
In 2024, 583 applications were received, slightly fewer than the 586 in the previous year, while 608 cases were processed, compared to 596 in 2023. This reduced the number of pending cases to 707 files (2023: 731). This figure demonstrates the continued confidence of multinationals in the Dutch system for obtaining tax certainty.
APAs in financial transactions and manufacturing
Two specific areas of the report stand out:
- Financial transactions: at least one APA was granted for loan transactions, with active involvement of local and group treasury teams, following a profit split analysis.
- Toll manufacturing: an APA was attempted using the cost-plus method, but was withdrawn as it was not possible to make reliable comparative adjustments to exclude raw material costs from the comparables.
Shift towards bilateral and multilateral APAs
A growing trend is confirmed: companies prefer bilateral or multilateral APAs over unilateral ones.
- Since 2019, unilateral APAs have faced stricter requirements and longer resolution times (12 months on average).
- Companies are seeking greater certainty and protection against double taxation.
- Bilateral APAs take approximately 32 months (compared to 40 months in 2023).
Overall reduction in response times
The report indicates that the average processing time for APAs—whether unilateral, bilateral, or multilateral—has decreased, as has that for other types of tax rulings. This reflects more effective management of the system.
Conclusion
In summary, the 2024 Annual Report confirms that:
- Demand for APAs remains strong.
- There are successful cases, especially in finance and manufacturing.
- There is a clear shift towards bilateral/multilateral APAs.
- Processing times are becoming increasingly efficient.
This scenario highlights the Netherlands’ position as a strong jurisdiction for obtaining transfer pricing certainty — especially in complex and cross-border structures.
Call to Action
At TPC Group, we have experience advising multinational companies on managing APA applications in the Netherlands. We can help you structure robust proposals, select the appropriate APA type, and navigate the process successfully. Contact us today to optimize your transfer pricing strategies.