M.M.P. Boreux - Mandatory Disclosure Rules in the Netherlands. - Circulaire

Mandatory Disclosure Rules in the Netherlands.

International tax issues have never been as high on the political agenda as they are nowadays. Countries cooperate intensively to combat Base Erosion and Profit Shifting. Within this context, numerous measures have appeared in recent years on which European or international consensus has been reached. One of these measures is the Mandatory Disclosure Rules which have recently been implemented throughout multiple jurisdictions in Europe. These new rules could constitute a permanent change in the relationship between the Tax Authorities on the one hand and intermediaries and taxpayers on the other hand. As a result of this new measure, cross-border arrangements that may indicate aggressive tax planning must be reported beforehand to the Tax Authorities. Throughout this thesis, the Dutch implementation of the Mandatory Disclosure Rules will be critically analysed. In addition, the Dutch implementation will also be subjected to a legal comparison with the Mandatory Disclosure Rules in other countries. This thesis results from the author his participation in the EUCOTAX Wintercourse.