Netherlands - Reports MAP Outcomes and Tax Dispute Resolution Procedures for 2025

Summary

The Dutch Tax and Customs Administration (Belastingdienst) published the Mutual Agreement Procedure (MAP) Annual Report 2025, reporting on the Netherlands’ mutual agreement procedure activities during 2025, including procedures for resolving international tax disputes and eliminating double taxation. The report states that 97% of MAP cases in the Netherlands were successfully resolved in 2025 and provides information on MAP case volumes, case categories, pre-filing meetings, interest mitigation requests, and jurisdictions with the highest number of MAP cases.

Key points

MAP Case Volume and Resolution Results

The MAP Annual Report 2025 provides information on the volume and resolution of MAP cases handled by the Netherlands in 2025.

In 2025, the Dutch MAP team received 506 MAP requests and completed 531 MAP cases.

According to the report, 97% of MAP cases in the Netherlands were successfully resolved in 2025.

The MAP procedure is used by competent authorities to resolve disputes arising from the interpretation or application of tax treaties and to eliminate double taxation.

Types of MAP Cases

The report provides information on MAP cases involving international tax disputes.

The MAP cases covered by the report include matters relating to:

• Transfer pricing disputes;

• Interpretation or application of tax treaty provisions; and

• Corporate residence issues involving treaty tie-breaker provisions.

Availability of Pre-Filing Meetings

The report describes the availability of pre-filing meetings before the formal submission of MAP, bilateral advance pricing agreement (BAPA), or multilateral advance pricing agreement (MAPA) requests.

Taxpayers may engage in informal and non-binding discussions with the Dutch tax authorities before submitting a formal request.

The discussions address procedural aspects and the suitability of submitting a request under the relevant circumstances.

MAP Resolution Period

The report provides information regarding the timeframe for resolving MAP cases.

The Netherlands applies the international standard under which MAP cases are generally resolved within 24 months.

The report provides information on the Netherlands’ MAP performance in relation to this timeframe.

Interest Mitigation in MAP Cases

The report provides information regarding requests for mitigation of tax interest or collection interest in MAP cases.

Taxpayers may request mitigation of tax interest or collection interest charged in the Netherlands in connection with MAP cases.

The report notes that this possibility is generally not available in bilateral advance pricing agreement (BAPA) or multilateral advance pricing agreement (MAPA) cases.

Jurisdictions with the Highest Number of MAP Cases

The report identifies the jurisdictions with which the Netherlands had the highest number of MAP cases in 2025.

The five jurisdictions with the highest number of MAP cases were:

• Belgium;

• Germany;

• France;

• United Kingdom; and

• United States.

MAP and Advance Pricing Agreement Procedures

The report includes information regarding procedures administered by the Netherlands for resolving international tax disputes and addressing double taxation.

The procedures covered include:

• Mutual Agreement Procedures (MAP);

• Bilateral Advance Pricing Agreements (BAPA); and

• Multilateral Advance Pricing Agreements (MAPA).

Source:

Dutch Tax and Customs Administration (Belastingdienst), Mutual Agreement Procedure (MAP) Annual Report 2025

https://www.belastingdienst.nl/

--------------------------------------------

Disclaimer:

This content is for general informational purposes only and does not constitute professional advice.

Information provided herein is based on publicly available sources as of the publication date and may be subject to change.

Armize consulting | Transfer Pricing