The Dutch government issued the Annual Report 2024 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.
Constant Number of APA Applications
In 2024, 583 applications were received, slightly lower than the 586 received the previous year, while 608 cases were processed, compared to 596 in 2023. It reduced the number of pending cases to 707 files (2023: 731). This data demonstrates the continued confidence of multinationals in the Dutch regime 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 the active participation of local and group treasury teams, following a profit split analysis.
- Toll manufacturing: An APA using the cost-plus method was attempted, but was withdrawn as it was not possible to make reliable comparative adjustments to exclude raw material costs from the comparables.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 larger resolutions (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 APA processing—whether unilateral, bilateral, or multilateral—has decreased, as has that of other types of tax rulings. It reflects more effective management of the system.
Conclusion
In summary, the Annual Report 2024 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.
- Management times are increasingly efficient.
This scenario highlights the Netherlands 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 strong proposals, select the appropriate type of APA, and successfully navigate the process. Contact us today to optimize your Transfer Pricing strategies.
Source: Meijburg