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[{"$f":"\"Niet dit document, maar de XML (na valideren) insturen naar: \" & Configuratie!B7","v":"Niet dit document, maar de XML (na valideren) insturen naar: exchange-tax-rulings@belastingdienst.nl"}]
[null,null,"Een gegeven dat is gemarkeerd met een * is verplicht (datafield marked with an * is mandatory)"]
["E X C H A N G E   T A X    R U L I N G S - invulsjabloon, versie 6.2"]
[null,"Ruling type for this form*",null,null,null,null,null,"RAVopmerkingen"]
[]
["Competent inspector*","Behandelend inspecteur*",""]
[]
["Contact details","Contactgegevens invuller"]
["Organisation*","Organisatie*","",null,null,"ID = land AE & finr & volgnummer AE & rulingnr & ExchRn"]
["Name*","Naam*",""]
["E-mail address*","E-mail adres*",""]
["Phone number*","Telefoonnummer*",""]
[]
["TaxPayer","Belastingplichtige"]
["TIN*","RSIN*","",null,null,"finr; controle op getal",null,"zit in RAV export"]
["OrganisationName*","Naam*","",null,null,"tekst",null,"zit in RAV export"]
["Street*","Straat en huisnummer*","",null,null,"tekst",null,"kan in RAV export?"]
["PostCode*","Postcode*","",null,null,"tekst",null,"kan in RAV export?"]
["City*","Vestigingsplaats*",""]
["ResCountry*","Vestigingsland*","Vul in of kies een item >>>",{"$f":"VLOOKUP(C20,Validation!$C$102:$D$350,2,FALSE)","v":{"$error":"#N/A"}},"ResCountryCode","Nederland voorinvullen",null,"kan in RAV export?"]
[]
["BizActivities","Activiteiten onderneming","Kies een item >>>",{"$f":"LEFT(C22,6)","v":"Kies e"},null,null,null,"pulldown maken RAV"]
["OtherBizActivityInfo","Toelichting bij keuze \"ETR514 - Other\"*","",null,null,"tekst"]
["GroupName*","Groepsnaam*","",null,null,"tekst"]
["TurnOver","Omzet  (bedrag valutasoort)","","Valuta…","TurnOverCurrCode","getal; controle op getal"]
["ProfitOrLoss","Winst of Verlies  (bedrag valutasoort)","","Valuta…","ProfitOrLossCurrCode","getal; controle op getal"]
[]
["RulingReport","Ruling"]
["RulingNumber","Rulingnummer","",null,null,"tekst",null,"zit in RAV export"]
["Validity StartDate","Overeenkomst geldig van",null,null,null,"datum met controle",null,"zit in RAV export"]
["Validity EndDate","Overeenkomst geldig t/m",null,null,null,"datum met controle",null,"zit in RAV export"]
[]
["ATRorAPAorOtherRuling*","Is het een ATR, een APA of een overige ruling*","Kies een item >>>",{"$f":"LEFT(C33,7)","v":"Kies ee"},null,"controle op keuze",null,"kan in RAV export? - classificatie OF pulldown maken RAV - géén pulldown - we hebben geen combi! Afspraak Eric."]
["RulingCategory*","ATR of APA soort*","Kies een item >>>",{"$f":"LEFT(C34,6)","v":"Kies e"},"EEN combi lijst","controle op keuze",null,"pulldown maken RAV"]
["RulingTypeInfo","Toelichting bij keuze \"ETR609 - Other\"*","Typ of kies uit de lijst en vul (evt.) aan >>>",null,null,"Opent bij 609"]
["TransactionAmount","Transactiebedrag (bedrag valutasoort)","","Valuta…","TransactionAmountCurrCode"]
["Summary*","Samenvatting APA of ATR*","Typ of kies uit de lijst en/of vul aan >>>",null,null,"tekst"]
[]
["EUAPAInfo"]
["EUCriteria","Criteria vaststellen verrekenprijzen","Kies een item >>>"]
["EUMethod","TP methode van de APA","Kies een item >>>",{"$f":"LEFT(C41,7)","v":"Kies ee"},null,"controle op keuze",null,"pulldown maken RAV"]
[]
["ReceivingJurisdictions"]
["AffectedEntity_1",null,null,null,"ID"]
["ExchangeReason*","Reden uitwisseling*","Kies een item >>>  ",{"$f":"LEFT(C45,6)","v":"Kies e"},null,"controle op keuze"]
["AffectedEntityTIN*","RSIN*",""]
["AffectedEntityOrganisationName*","Naam*",""]
["AffectedEntityStreet","Straat en huisnummer",""]
["AffectedEntityPostCode","Postcode",""]
["AffectedEntityCity*","Vestigingsplaats*",""]
["AffectedEntityResCountry*","Vestigingsland*","Vul in of kies een item >>>",{"$f":"VLOOKUP(C51,Validation!$C$102:$D$350,2,FALSE)","v":{"$error":"#N/A"}}]
["Double click to add other entities"]

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[null,"Blauw = referentiedata RAV"]
[]
[null,"BizActivities","Kies een item >>>  ",null,null,"RulingTypeInfo","Typ of kies uit de lijst en vul (evt.) aan >>>"]
[null,null,"ETR501 – Research and Development",null,null,"LIJST ALS KEUZE IS ","Participation exemption - parent-subsidiary directive"]
[null,null,"ETR502 – Holding or Managing intellectual property",null,null,"609 [EU-ONLY] - Other","Dividend withholding tax - other withholding tax"]
[null,null,"ETR503 – Purchasing or Procurement",null,null,null,"Foreign tax liability - tax residency"]
[null,null,"ETR504 – Manufacturing or Production",null,null,null,"Determination (non)transparency"]
[null,null,"ETR505 – Sales, Marketing or Distribution",null,null,null,"Tax treatment hybrid loan"]
[null,null,"ETR506 – Administrative, Management or Support Services",null,null,null,"Attribution of shares to permanent establishment"]
[null,null,"ETR507 – Provision of Services to unrelated parties",null,null,null,"business restructurings - reorganization of company structure"]
[null,null,"ETR508 – Internal Group Finance",null,null,null,"Tax deductible costs - tax deductibility of expenditures (including financial expenses)"]
[null,null,"ETR509 – Regulated Financial Services",null,null,null,"Exit taxation"]
[null,null,"ETR510 – Insurance",null,null,null,"Ruling-APA regarding tax anti-avoidance measures of the Member State, including the GAAR"]
[null,null,"ETR511 – Holding shares or other equity instruments"]
[null,null,"ETR512 – Dormant"]
[null,null,"ETR513 – e-Commerce"]
[null,null,"ETR514 - Other"]
[]
[]
[null,"ATRorAPA","Kies een item >>>  "]
[null,null,"ETR1001 – Advance tax ruling"]
[null,null,"ETR1002 – Advance pricing arrangement"]
[null,null,"ETR1003 – Combined ruling and APA"]
[null,null,"ETR1004 – Not classified"]
[null,null,null,null,null,null,"Voor tonnage is de keuze beperkt:",null,"Voor innovation is de keuze beperkt:"]
[null,"RulingCategory","Kies een item >>>  ",null,null,null,"ETR601 [OECD and EU] - Relating to preferential regime (tonnage)",null,"ETR601 [OECD and EU] - Relating to preferential regime (innovation)"]
[null,null,"ETR601 [OECD and EU] - Relating to preferential regime"]
[null,null,"ETR602 [OECD and EU] -  Unilateral APA or other TP ruling"]
[null,null,"ETR603 [EU-ONLY] - Bilateral or multilateral APA (ONLY to be used for exchanges under the EU framework)"]
[null,null,"ETR604 [EU-ONLY] - Exchange of summary information on request for bilateral or multilateral APA (ONLY to be used for exchanges under the EU framework)"]
[null,null,"ETR605 [OECD and EU] - Downward adjustment ruling"]
[null,null,"ETR606 [OECD and EU] - PE ruling"]
[null,null,"ETR608 [EU-ONLY] - Hybrid entity ruling (ONLY to be used for exchanges under the EU framework)"]
[null,null,"ETR609 [EU-ONLY] - Other"]
[null,"ETR607 [OECD and EU] - Conduit ruling",null,"In overleg met Minfin, uitgeschakeld (2018)"]
[]
[]
["EU","EUMethod","Kies een item >>>",null,null,null,"EUMethodInfo","Typ of kies uit de lijst en vul (evt.) aan >>>"]
[null,null,"ETR1101 – Comparable Uncontrolled Price Method (CUP)",null,null,null,"Opzet Aarnout","R&D - contract"]
[null,null,"ETR1102 – Resale Price Method (RSM)",null,null,null,"Als EUMethod = 1106 Other","R&D - own risk & account"]
[null,null,"ETR1103 – Cost Plus Method",null,null,null,null,"Sales - (marketing) agent"]
[null,null,"ETR1104 – Transactional Net Margin Method (TNMM)",null,null,null,"Vervalt in opzet Niels","Sales - limited risk distributor"]
[null,null,"ETR1105 – Transactional Profit Split Method (PSM)",null,null,null,null,"Sales - fully fledged"]
[null,"ETR1106 - Other",null,"komt niet voor! (Niels) (2018)",null,null,null,"Production - limited risk"]
[null,null,null,null,null,null,null,"Production - fully fledged"]
[null,null,null,null,null,null,null,"Headquarter - supportive"]
[null,"LegalBasisType","Kies een item >>>  ",null,null,null,null,"Headquarter - entrepreneurial"]
[null,null,"ETR801 – Multilateral Convention on Mutual Administrative Assistance in Tax Matters",null,null,null,null,"Logistics - supportive"]
[null,null,"ETR802 – EU Council Directive 2011/16/EU",null,null,null,null,"Logistics - entrepreneurial"]
[null,null,"ETR803 – Double taxation treaty",null,null,null,null,"IT - supportive"]
[null,null,"ETR804 – Tax information exchange agreement",null,null,null,null,"IT - entrepreneurial"]
[null,null,"ETR805 – Nordic Mutual Assistance Convention",null,null,null,null,"Other support functions"]
[null,null,"ETR806 – Other legal basis",null,null,null,null,"Mixed entrepreneurial functions"]
[]
[null,null,null,null,"Voor tonnage en innovation is de keuze beperkt:"]
[null,"ExchangeReason","Kies een item >>>  ",null,"Kies een item >>>  "]
[null,null,"ETR701 – Ultimate parent",null,"ETR701 – Ultimate parent"]
[null,null,"ETR702 – Immediate parent",null,"ETR702 – Immediate parent"]
[null,null,"ETR703 – Related party with which the taxpayer enters into a transaction for which a preferential treatment is granted or which gives rise to income benefiting from a preferential treatment",null,"ETR703 – Related party with which the taxpayer enters into a transaction for which a preferential treatment is granted or which gives rise to income benefiting from a preferential treatment"]
[null,null,"ETR704 – Related party with whom the taxpayer enters into a transaction covered by the ruling"]
[null,null,"ETR705 – Related party making payments to a conduit (directly or indirectly)"]
[null,null,"ETR706 – Ultimate beneficial owner of income from a conduit arrangement"]
[null,null,"ETR707 – Head office of permanent establishment/PE country"]
[null,null,"ETR708 – Exchange with EU Member States under Directive 2011/16/EU27"]
[null,null,null,null,null,null,null,null,null,null,null,null,null,"tonnage:","innovation:"]
["Summary","Summary","Typ of kies uit de lijst en/of vul aan >>>",null,"ETR601 [OECD and EU] - Relating to preferential regime","ETR602 [OECD and EU] -  Unilateral APA or other TP ruling","ETR603 [EU-ONLY] - Bilateral or multilateral APA (ONLY to be used for exchanges under the EU framework)","ETR604 [EU-ONLY] - Exchange of summary information on request for bilateral or multilateral APA (ONLY to be used for exchanges under the EU framework)","ETR605 [OECD and EU] - Downward adjustment ruling","ETR606 [OECD and EU] - PE ruling","ETR607 [OECD and EU] - Conduit ruling","ETR608 [EU-ONLY] - Hybrid entity ruling (ONLY to be used for exchanges under the EU framework)","ETR609 [EU-ONLY] - Other","ETR601 [OECD and EU] - Relating to preferential regime (tonnage)","ETR601 [OECD and EU] - Relating to preferential regime (innovation)"]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,2,FALSE)","v":{"$error":"#N/A"}},1,"1. 1-IVA / Afpelmethode \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the residual profit of ##NAME SHORT##, which can be allocated to this qualifying IP, is taxed under the Innovation Box regime The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[BTL routine/Sales] \nThe related party with whom the Taxpayer entered into the transaction covered by the ruling performs routine sales activities for the Taxpayer. These activities are remunerated by a TNMM with pli ROS (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Vaste inrichting [fixed place of business] \nThe activities of Taxpayer in the Netherlands constitute a permanent establishment for the Dutch Corporate Income Tax Act 1969 and the tax treaty that may apply.",null,"Kwalificatie rechtsvorm belastingplichtige [determination (non)transparency taxpayer] \nDetermination of the qualification of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer.","Deelnemingsvrijstelling [participation exemption] \nThe participation exemption (article 13 of the Dutch Corporate Income Tax Act 1969) is applicable to income (e.g. dividend and capital results) derived from the subsidiary of Taxpayer. The subsidiary is not held as a portfolio investment / should be considered a qualifying portfolio investment company (based on the asset test and/or subject-to-tax test) and therefore the participation exemption is applicable.","1. Vennootschap met standaard tonnageruling \n\"Tonnage Tax  Ruling (art. 3.22-3.24 Income Tax Code) ##NAME FULL##  is a Shipping company, focusing on ##MAIN ACTIVITY##, with offices in ##CITY## (NL), employing approx. ### FTE. These activities regard the strategic / commercial  / technical / crewing management with regard to ##NUMBER## seagoing vessels.  The benefits of the exploitation of these seagoing vessels qualify for the Tonnage Tax to the extent that these benefits relate to transportation activities. As a result the qualifing profits are taxed on the basis of the net tonnage of the ships being exploited by the company.”\n","1. 1-IVA / Afpelmethode \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the residual profit of ##NAME SHORT##, which can be allocated to this qualifying IP, is taxed under the Innovation Box regime The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”"]
[null,"RulingCategory",{"$f":"HLOOKUP($B$69,$E$66:$P$87,3,FALSE)","v":{"$error":"#N/A"}},2,"2. Cost+ \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the profit (calculated as a mark-up on the direct and indirect R&D costs) of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime. The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[BTL routine/Manufacturing] \nThe related party with whom the Taxpayer entered into the transaction covered by the ruling performs routine manufacturing  choose: contract / tolling) activities for the Taxpayer. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Negatieve v.i. [no fixed place of business] \nThe foreign taxpayer does not have a fixed place of business in the Netherlands, therefore there is no permanent establishment in the Netherlands. There is also no independent agent in the Netherlands.",null,"Kwalificatie rechtsvorm moedermaatschappij [determination (non)transparency parent] \nDetermination of the qualification of the immediate parent of Taxpayer as a transparent / non- transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer.","Dividendbelasting [dividend withholding tax] \nIn accordance with the Dutch Dividend Withholding Tax Act 1965 no Dutch dividend withholding tax is due on dividend distributions by Taxpayer. It was also established that there was no abuse of law. In accordance with the Dividend Withholding Tax Act 1965 Taxpayer must declare within one month after the moment the proceeds were made available that all conditions of the Dutch Dividend Withholding Tax Act 1965 are met. \n","2. Vennootschap met tonnageruling met winstsplitsingsafspraken \n\"Tonnage tax ruling (art. 3.22 IncomeTaxAct) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. The place of effective management of the company is in ##CITY## (NL), employing approx. ### FTE. The profits of the company from the operation of ships for the transport of goods and persons qualify for a taxation according to the tonnage tax regulations. These activities regard the strategic / commercial  / technical / crewing management with regard to ##NUMBER## seagoing vessels. The other profits from the operation of ships – being profits from activities other than the transport of goods and persons – are taxed according to the general rules  of the Income Tax Act.\nAs a result the shipping profits of ##NAME SHORT## are taxed on the basis of the net tonnage of the ships being exploited by the company. According to the tonnage tax ruling ###% of the total profits are taxed on a tonnage tax basis. The other profits from the operation of ships – amounting to ###% of the total profits - are taxed according to the general rules  of the Income Tax Act.”","2. Cost+ \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the profit (calculated as a mark-up on the direct and indirect R&D costs) of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime. The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”"]
[null,{"$f":"Template!C34","v":"Kies een item >>>"},{"$f":"HLOOKUP($B$69,$E$66:$P$87,4,FALSE)","v":{"$error":"#N/A"}},3,"3. Royaltybenadering \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the net royalty income of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime.  The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[BTL routine/Other] \nThe related party with whom the Taxpayer entered into the transaction covered by the ruling performs routine services (choose: sales support / purchasing / contract R&D / headquarters / other) activities for the Taxpayer. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Negatieve v.i. [prepartory/auxiliary character] \nThe foreign taxpayer does  have a fixed place of business in the Netherlands, but the overall activity of the fixed place of business is of a preparatory or auxiliary character. Therefore there is no permanent establishment in the Netherlands. There is also no independent agent in the Netherlands.",null,"Kwalificatie rechtsvorm deelneming [determination (non)transparency subsidiary] \nDetermination of the qualification of the direct subsidiary of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer.","Dividendbelasting houdstercoöperatie [dividend withholding tax holding cooperative] \nTaxpayer qualifies as a 'holding cooperative' and is in principle subject to Dutch dividend withholding tax (15%). A cooperative that is not sufficiently actively involved in the management of its investments and that has sufficient (qualitative and quantitative) presence in the Netherlands (such as personnel and an office) qualifies as a 'holding cooperative'.\n",null,"3. Royaltybenadering \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the net royalty income of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime.  The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”"]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,5,FALSE)","v":{"$error":"#N/A"}},4,"4. Other \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the profit of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime. This part of the profit is calculated according to the following method: ##BRIEF DESCRIPTION METHOD (NOT BEING 1 – 4)##. The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[NL routine/Sales] \nThe Taxpayer performs routine sales activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli ROS (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Negatieve v.i. [no fixed place of business/home-office] \nThe foreign taxpayer (the employer of (an) individual(s)) does not have a fixed place of business in the Netherlands, because the home office of the employee(s) is not at the disposal of the employer. Therefore there is no permanent establishment in the Netherlands. There is also no independent agent in the Netherlands.",null,null,"Dividendbelasting niet houdstercoöperatie [dividend withholding tax non-holding cooperative] \nTaxpayer qualifies as a 'non-holding cooperative' and is not subject to Dutch dividend withholding tax. A cooperative that is sufficiently actively involved in the management of its investments and that has sufficient (qualitative and quantitative) presence in the Netherlands (such as personnel and an office) qualifies as a 'non-holding cooperative'.\n",null,"4. Other \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the profit of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime. This part of the profit is calculated according to the following method: ##BRIEF DESCRIPTION METHOD (NOT BEING 1 – 4)##. The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”"]
[null,"Aangeboden",{"$f":"HLOOKUP($B$69,$E$66:$P$87,6,FALSE)","v":{"$error":"#N/A"}},5,"5. Vennootschap met standaard tonnageruling \n\"Tonnage Tax  Ruling (art. 3.22-3.24 Income Tax Code) ##NAME FULL##  is a Shipping company, focusing on ##MAIN ACTIVITY##, with offices in ##CITY## (NL), employing approx. ### FTE. These activities regard the strategic / commercial  / technical / crewing management with regard to ##NUMBER## seagoing vessels.  The benefits of the exploitation of these seagoing vessels qualify for the Tonnage Tax to the extent that these benefits relate to transportation activities. As a result the qualifing profits are taxed on the basis of the net tonnage of the ships being exploited by the company.”\n","[NL routine/Subprincipaal] \nThe Taxpayer performs routine sales activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli ROS (...%) which is within the interquartile range which ranges from (...%) until (...%). The difference between the actual result and the remuneration as agreed upon is deductible for corporate income tax purposes.",null,null,null,"Beloning vaste inrichting [renumeration fixed place of business] \nThe activities of the permanent establishment of Taxpayer are remunerated on an at arm’s length basis.",null,null,"Dividendbelasting [dividend withholding tax] \nDetermination of the applicable rate XX%* of Dutch dividend withholding tax on dividend distributions by Taxpayer in accordance with the tax treaty between the Netherlands and the country of residence of the immediate parent of Taxpayer. The immediate taxpayer holds an interest of XX%* in Taxpayer."]
[null,"Summary",{"$f":"HLOOKUP($B$69,$E$66:$P$87,7,FALSE)","v":{"$error":"#N/A"}},6,"6. Vennootschap met tonnageruling met winstsplitsingsafspraken \n\"Tonnage tax ruling (art. 3.22 IncomeTaxAct) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. The place of effective management of the company is in ##CITY## (NL), employing approx. ### FTE. The profits of the company from the operation of ships for the transport of goods and persons qualify for a taxation according to the tonnage tax regulations. These activities regard the strategic / commercial  / technical / crewing management with regard to ##NUMBER## seagoing vessels. The other profits from the operation of ships – being profits from activities other than the transport of goods and persons – are taxed according to the general rules  of the Income Tax Act.\nAs a result the shipping profits of ##NAME SHORT## are taxed on the basis of the net tonnage of the ships being exploited by the company. According to the tonnage tax ruling ###% of the total profits are taxed on a tonnage tax basis. The other profits from the operation of ships – amounting to ###% of the total profits - are taxed according to the general rules  of the Income Tax Act.”","[NL routine/Manufacturing] \nThe Taxpayer performs routine manufacturing (choose: contract / tolling) activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,null,null,null,"Vangnetbepaling [application tax treaty] \nThe Taxpayer has been granted the benefits of the Country* – Netherlands tax treaty. Obtaining the benefits of that tax treaty has not been one of the principal purposes in the establishment, acquisition or maintenance of the TaxPayer or the conduct of its operations."]
[null,"afhankelijk van",{"$f":"HLOOKUP($B$69,$E$66:$P$87,8,FALSE)","v":{"$error":"#N/A"}},7,null,"[NL routine/Other] \nThe Taxpayer performs routine services (choose: sales support / purchasing / contract R&D / headquarters / other) activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,null,null,null,"Buitenlandse belastingplicht [foreign tax liability parent] \nThe immediate parent(s) of Taxpayer is/are not liable to Dutch corporate income  tax (articles 17 and 17a of the Dutch Corporate Income Tax Act 1969) for income derived  from a substantial shareholding/membership rights. Articles 17 and 17a of the Dutch Corporate Income Tax Act 1969 can be regarded as anti-abuse provisions. In this specific case there is no abuse of law."]
[null,"keuze RulCat.",{"$f":"HLOOKUP($B$69,$E$66:$P$87,9,FALSE)","v":{"$error":"#N/A"}},8,null,"[DVL-financing] \nThe Taxpayer provides financing activities for group companies. The Taxpayer receives a gross remuneration for these services amounting to ... bps over the outstanding loans.",null,null,null,null,null,null,"Buitenlandse belastingplicht bel.pl. [foreign tax liability taxpayer]\nTaxpayer (the immediate parent of the Dutch company) is not liable to Dutch corporate income tax (articles 17 and 17a of the Dutch Corporate Income Tax Act 1969) for income derived  from a substantial shareholding/membership rights. Articles 17 and 17a of the Dutch Corporate Income Tax Act 1969 can be regarded as anti-abuse provisions. In this specific case there is no abuse of law."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,10,FALSE)","v":{"$error":"#N/A"}},9,null,"[DVL-royalties] \nThe Taxpayer provides licensing activities for group companies. The Taxpayer receives a gross remuneration for these services amounting to ... bps over the incoming royalties.",null,null,null,null,null,null,"Hybride financiering [tax treatment hybrid loan - 1]\nDue to the loan conditions, the loan from Taxpayer qualifies for tax purposes as equity. As a result, the participation exemption (article 13 of the Dutch Corporate Income Tax Act 1969) will be applicable on income derived from this loan. In short: (i) the term of the loan is longer than 50 years or the loan has no maturity date, (ii) the interest is profit depending and (iii) the loan is subordinated to all other creditors and is only due and payable by bankruptcy, suspension of payment or liquidation.\n"]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,11,FALSE)","v":{"$error":"#N/A"}},10,null,"[Profit Split] \nDue to the interrelated nature of (i) the functions performed (including the attribution of assets and risks) of the Taxpayer and the related party with whom the Taxpayer entered into the transaction covered by the ruling and (ii) the contributions made by both parties, it is agreed that the result (residual profit or loss) will be split between the related party (... %) and Taxpayer (...%).",null,null,null,null,null,null,"Hybride financiering [tax treatment hybrid loan - 2]\nDue to the loan conditions the loan to Taxpayer qualifies for tax purposes as equity. In short: (i) the term of the loan is longer than 50 years or the loan has no maturity date, (ii) the interest is profit depending and (iii) the loan is subordinated to all other creditors and is only due and payable by bankruptcy, suspension of payment or liquidation.\n"]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,12,FALSE)","v":{"$error":"#N/A"}},11,null,"Other \n(for example: infokap/winstallocatie vi/afwijkende pli).",null,null,null,null,null,null,"Toerekening aandelen aan vaste inrichting [attribution of shares to permanent establishment] \nThe shares of the direct subsidiary of taxpayer are attributable to a permanent establishment of Taxpayer in the Netherlands.\n"]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,13,FALSE)","v":{"$error":"#N/A"}},12,null,null,null,null,null,null,null,null,"Kwalificatie rechtsvorm belastingplichtige [determination (non)transparency taxpayer] \nDetermination of the qualification of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,14,FALSE)","v":{"$error":"#N/A"}},13,null,null,null,null,null,null,null,null,"Kwalificatie rechtsvorm moedermaatschappij [determination (non)transparency parent] \nDetermination of the qualification of the immediate parent of Taxpayer as a transparent / non- transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,15,FALSE)","v":{"$error":"#N/A"}},14,null,null,null,null,null,null,null,null,"Kwalificatie rechtsvorm deelneming [determination (non)transparency subsidiary] \nDetermination of the qualification of the direct subsidiary of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,16,FALSE)","v":{"$error":"#N/A"}},15,null,null,null,null,null,null,null,null,"Overige rulings m.b.t. pensioenvrijstelling [Other rulings - Pension exemption] \n##NAME FULL## is comparable to a Dutch pension fund and therefore exempt from Dutch corporate income tax as a foreign taxpayer."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,17,FALSE)","v":{"$error":"#N/A"}},16,null,null,null,null,null,null,null,null,"Overige rulings m.b.t. renteaftrekbeperkingen (10a) [Other rulings - interest deduction limitation] \nThe intercompany loan between ##NAME FULL## and ##NAME FULL## falls within the scope of the Dutch anti-base erosion rules. However, ##NAME FULL## can successfully invoke a counter-evidence rule. As a result, the interest is not restricted in deduction under the Dutch anti-base erosion rules."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,18,FALSE)","v":{"$error":"#N/A"}},17,null,null,null,null,null,null,null,null,"Overige rulings m.b.t. vestigingsplaats en de vestigingsplaatsfictie [Other rulings - place of residence and residence fiction] \n......."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,19,FALSE)","v":{"$error":"#N/A"}},18,null,null,null,null,null,null,null,null,"Overige rulings m.b.t. grensoverschrijdende fusie [Other rulings -crossborder merger] \nConfirmation of the Dutch corporate income tax and/or Dutch dividend tax treatment with regard to the cross-border merger of ##NAME FULL## into ##NAME FULL##."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,20,FALSE)","v":{"$error":"#N/A"}},19,null,null,null,null,null,null,null,null,"ATAD2  \nHybrid entity mismatch rules (ATAD2) do not apply to payments made by ##NAME FULL NL entity## to ##NAME FULL Foreign company##."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,21,FALSE)","v":{"$error":"#N/A"}},20,null,null,null,null,null,null,null,null,"Conditionele bronbelasting op dividenden [(conditional) withholding tax on dividends] \nIn accordance with the Withholding Tax Act 2021 no Dutch withholding tax is due on dividend payments by Taxpayer to its member as from 1 January 2024. In this specific case there is no abuse of law."]
[null,null,{"$f":"HLOOKUP($B$69,$E$66:$P$87,22,FALSE)","v":{"$error":"#N/A"}},21,null,null,null,null,null,null,null,null,"Artikel 8ba-8bd Wet Vpb [Article 8ba-8bd CITA] \nA capital contribution of cash into the Taxpayer does not lead to corporate income tax being due in the Netherlands as there is no value difference to which the anti-transfer pricing mismatches rules (Articles 8ba-8bd of the Corporate Income Tax Act) apply. Article 8bd Dutch Corporate Income Tax Act 1969 in principle targets mismatches that could arise due to valuation differences on the transfer of assets through acts such as capital contributions, dividend distributions and liquidation distributions and comparable. In short, the article stipulates that when a Dutch taxpayer acquires an asset from an associated entity by way of acts such as a capital contribution, the Dutch taxpayer is obliged to record the acquired asset in its Dutch tax base for the value taken into account in a profit tax by the contributing/distributing entity."]
[]
[null,"EUCriteria>>>",null,null,null,null,"EUCriteria","Niels:","EUCriteria"]
[null,null,null,null,null,null,null,"Kies een item >>>","Opzet Aarnout"]
[null,null,null,null,null,null,null,"Routine",null,"Functions : Limited; Assets : Limited; Risks : Limited."]
[null,null,null,null,null,null,null,"Entrepreneurial (or non-routine)",null,"Functions : Limited; Assets : Limited; Risks : Medium."]
[null,null,null,null,null,null,null,"Other",null,"Functions : Limited; Assets : Limited; Risks : High."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : Limited; Risks : Full."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : Medium; Risks : Limited."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : Medium; Risks : Medium."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : Medium; Risks : High."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : Medium; Risks : Full."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : High; Risks : Limited."]
[null,null,null,null,null,null,null,null,null,"Functions : Limited; Assets : High; Risks : Medium."]
[null,"Land","Vul in of kies een item >>>",null,null,"Valuta","Valuta…",null,null,"Functions : Limited; Assets : High; Risks : High."]
[null,"LegalBasisType","Afghanistan","AF",null,null,"AED","VAE-dirham",null,"Functions : Limited; Assets : High; Risks : Full."]
[null,null,"Åland","AX",null,null,"AFN","Afghani",null,"Functions : Limited; Assets : Full; Risks : Limited."]
[null,null,"Albanië","AL",null,null,"ALL","Albanese lek",null,"Functions : Limited; Assets : Full; Risks : Medium."]
[null,null,"Algerije","DZ",null,null,"AMD","Armeense dram",null,"Functions : Limited; Assets : Full; Risks : High."]
[null,null,"Amerikaanse Maagdeneilanden","VI",null,null,"ANG","Antilliaanse gulden",null,"Functions : Limited; Assets : Full; Risks : Full."]
[null,null,"Amerikaans-Samoa","AS",null,null,"AOA","Angolese kwanza",null,"Functions : Medium; Assets : Limited; Risks : Limited."]
[null,null,"Andorra","AD",null,null,"ARS","Argentijnse peso",null,"Functions : Medium; Assets : Limited; Risks : Medium."]
[null,null,"Angola","AO",null,null,"AUD","Australische dollar",null,"Functions : Medium; Assets : Limited; Risks : High."]
[null,null,"Anguilla","AI",null,null,"AWG","Arubaanse gulden",null,"Functions : Medium; Assets : Limited; Risks : Full."]
[null,null,"Antarctica","AQ",null,null,"AZN","Azerbeidzjaanse manat",null,"Functions : Medium; Assets : Medium; Risks : Limited."]
[null,null,"Antigua en Barbuda","AG",null,null,"BAM","Bosnische mark",null,"Functions : Medium; Assets : Medium; Risks : Medium."]
[null,null,"Argentinië","AR",null,null,"BBD","Barbadiaanse dollar",null,"Functions : Medium; Assets : Medium; Risks : High."]
[null,null,"Armenië","AM",null,null,"BDT","Bengalese taka",null,"Functions : Medium; Assets : Medium; Risks : Full."]
[null,null,"Aruba","AW",null,null,"BGN","Nieuwe Bulgaarse lev (sinds 1999)",null,"Functions : Medium; Assets : High; Risks : Limited."]
[null,null,"Australië","AU",null,null,"BHD","Bahreinse dinar",null,"Functions : Medium; Assets : High; Risks : Medium."]
[null,null,"Azerbeidzjan","AZ",null,null,"BIF","Burundese frank",null,"Functions : Medium; Assets : High; Risks : High."]
[null,null,"Bahama's","BS",null,null,"BMD","Bermudaanse dollar",null,"Functions : Medium; Assets : High; Risks : Full."]
[null,null,"Bahrein","BH",null,null,"BND","Bruneise dollar",null,"Functions : Medium; Assets : Full; Risks : Limited."]
[null,null,"Bangladesh","BD",null,null,"BOB","Boliviaanse boliviano",null,"Functions : Medium; Assets : Full; Risks : Medium."]
[null,null,"Barbados","BB",null,null,"BOV","Boliviaanse Mvdol (aandelen)",null,"Functions : Medium; Assets : Full; Risks : High."]
[null,null,"België","BE",null,null,"BRL","Braziliaanse real",null,"Functions : Medium; Assets : Full; Risks : Full."]
[null,null,"Belize","BZ",null,null,"BSD","Bahamaanse dollar",null,"Functions : High; Assets : Limited; Risks : Limited."]
[null,null,"Benin","BJ",null,null,"BTN","Bhutaanse ngultrum",null,"Functions : High; Assets : Limited; Risks : Medium."]
[null,null,"Bermuda","BM",null,null,"BWP","Botswaanse pula",null,"Functions : High; Assets : Limited; Risks : High."]
[null,null,"Bhutan","BT",null,null,"BYR","Wit-Russische roebel",null,"Functions : High; Assets : Limited; Risks : Full."]
[null,null,"Bolivia","BO",null,null,"BZD","Belizaanse dollar",null,"Functions : High; Assets : Medium; Risks : Limited."]
[null,null,"Bonaire, Sint Eustatius en Saba","BQ",null,null,"CAD","Canadese dollar",null,"Functions : High; Assets : Medium; Risks : Medium."]
[null,null,"Bosnië en Herzegovina","BA",null,null,"CDF","Congolese frank",null,"Functions : High; Assets : Medium; Risks : High."]
[null,null,"Botswana","BW",null,null,"CHF","Zwitserse frank",null,"Functions : High; Assets : Medium; Risks : Full."]
[null,null,"Bouveteiland","BV",null,null,"CLF","Chileense Unidades de fomento (aandelen)",null,"Functions : High; Assets : High; Risks : Limited."]
[null,null,"Brazilië","BR",null,null,"CLP","Chileense peso",null,"Functions : High; Assets : High; Risks : Medium."]
[null,null,"Brits Indische Oceaanterritorium","IO",null,null,"CNY","Chinese yuan",null,"Functions : High; Assets : High; Risks : High."]
[null,null,"Britse Maagdeneilanden","VG",null,null,"COP","Colombiaanse peso",null,"Functions : High; Assets : High; Risks : Full."]
[null,null,"Brunei","BN",null,null,"COU","Colombiaanse unidad de valor real",null,"Functions : High; Assets : Full; Risks : Limited."]
[null,null,"Bulgarije","BG",null,null,"CRC","Costa Ricaanse colon",null,"Functions : High; Assets : Full; Risks : Medium."]
[null,null,"Burkina Faso","BF",null,null,"CUC","Convertibele peso (munteenheid voor toeristen in Cuba)",null,"Functions : High; Assets : Full; Risks : High."]
[null,null,"Burundi","BI",null,null,"CUP","Cubaanse peso",null,"Functions : High; Assets : Full; Risks : Full."]
[null,null,"Cambodja","KH",null,null,"CVE","Kaapverdische escudo",null,"Functions : Full; Assets : Limited; Risks : Limited."]
[null,null,"Canada","CA",null,null,"CZK","Tsjechische kroon",null,"Functions : Full; Assets : Limited; Risks : Medium."]
[null,null,"Centraal-Afrikaanse Republiek","CF",null,null,"DJF","Djiboutiaanse frank",null,"Functions : Full; Assets : Limited; Risks : High."]
[null,null,"Chili","CL",null,null,"DKK","Deense kroon",null,"Functions : Full; Assets : Limited; Risks : Full."]
[null,null,"China","CN",null,null,"DOP","Dominicaanse peso",null,"Functions : Full; Assets : Medium; Risks : Limited."]
[null,null,"Christmaseiland","CX",null,null,"DZD","Algerijnse dinar",null,"Functions : Full; Assets : Medium; Risks : Medium."]
[null,null,"Cocoseilanden","CC",null,null,"EGP","Egyptisch pond",null,"Functions : Full; Assets : Medium; Risks : High."]
[null,null,"Colombia","CO",null,null,"ERN","Eritrese nakfa",null,"Functions : Full; Assets : Medium; Risks : Full."]
[null,null,"Comoren","KM",null,null,"ETB","Ethiopische birr",null,"Functions : Full; Assets : High; Risks : Limited."]
[null,null,"Congo-Brazzaville","CG",null,null,"EUR","Euro",null,"Functions : Full; Assets : High; Risks : Medium."]
[null,null,"Congo-Kinshasa","CD",null,null,"FJD","Fiji-dollar",null,"Functions : Full; Assets : High; Risks : High."]
[null,null,"Cookeilanden","CK",null,null,"FKP","Falklandeilands pond",null,"Functions : Full; Assets : High; Risks : Full."]
[null,null,"Costa Rica","CR",null,null,"GBP","Brits pond sterling",null,"Functions : Full; Assets : Full; Risks : Limited."]
[null,null,"Cuba","CU",null,null,"GEL","Georgische lari",null,"Functions : Full; Assets : Full; Risks : Medium."]
[null,null,"Curaçao","CW",null,null,"GHS","Ghanese cedi (Geldig per 1 juli 2007, 1 GHS = 10.000 GHC)",null,"Functions : Full; Assets : Full; Risks : High."]
[null,null,"Cyprus","CY",null,null,"GIP","Gibraltarees pond",null,"Functions : Full; Assets : Full; Risks : Full."]
[null,null,"Denemarken","DK",null,null,"GMD","Gambiaanse dalasi"]
[null,null,"Djibouti","DJ",null,null,"GNF","Guineese frank"]
[null,null,"Dominica","DM",null,null,"GTQ","Guatemalaanse quetzal"]
[null,null,"Dominicaanse Republiek","DO",null,null,"GYD","Guyaanse dollar"]
[null,null,"Duitsland","DE",null,null,"HKD","Hongkongse dollar"]
[null,null,"Ecuador","EC",null,null,"HNL","Hondurese lempira"]
[null,null,"Egypte","EG",null,null,"HRK","Kroatische kuna"]
[null,null,"El Salvador","SV",null,null,"HTG","Haïtiaanse gourde"]
[null,null,"Equatoriaal-Guinea","GQ",null,null,"HUF","Hongaarse forint"]
[null,null,"Eritrea","ER",null,null,"IDR","Indonesische roepia"]
[null,null,"Estland","EE",null,null,"ILS","Nieuwe Israëlische sjekel"]
[null,null,"Eswatini (Kingdom of)","SZ",null,null,"INR","Indiase roepie"]
[null,null,"Ethiopië","ET",null,null,"IQD","Iraakse dinar"]
[null,null,"Faeröer","FO",null,null,"IRR","Iraanse rial"]
[null,null,"Falklandeilanden","FK",null,null,"ISK","IJslandse kroon"]
[null,null,"Fiji","FJ",null,null,"JMD","Jamaicaanse dollar"]
[null,null,"Filipijnen","PH",null,null,"JOD","Jordaanse dinar"]
[null,null,"Finland","FI",null,null,"JPY","Japanse yen"]
[null,null,"Frankrijk","FR",null,null,"KES","Keniaanse shilling"]
[null,null,"Franse Zuidelijke en Antarctische Gebieden","TF",null,null,"KGS","Kirgizische som"]
[null,null,"Frans-Guyana","GF",null,null,"KHR","Cambodjaanse riel"]
[null,null,"Frans-Polynesië","PF",null,null,"KMF","Comorese frank"]
[null,null,"Gabon","GA",null,null,"KPW","Noord-Koreaanse won"]
[null,null,"Gambia","GM",null,null,"KRW","Zuid-Koreaanse won"]
[null,null,"Georgië","GE",null,null,"KWD","Koeweitse dinar"]
[null,null,"Ghana","GH",null,null,"KYD","Kaaimaneilandse dollar"]
[null,null,"Gibraltar","GI",null,null,"KZT","Kazachse tenge"]
[null,null,"Grenada","GD",null,null,"LAK","Laotiaanse kip"]
[null,null,"Griekenland","GR",null,null,"LBP","Libanees pond"]
[null,null,"Groenland","GL",null,null,"LKR","Sri Lankaanse roepie"]
[null,null,"Guadeloupe","GP",null,null,"LRD","Liberiaanse dollar"]
[null,null,"Guam","GU",null,null,"LSL","Lesothaanse loti"]
[null,null,"Guatemala","GT",null,null,"LTL","Litouwse litas"]
[null,null,"Guernsey","GG",null,null,"LVL","Letse lats"]
[null,null,"Guinee","GN",null,null,"LYD","Libische dinar"]
[null,null,"Guinee-Bissau","GW",null,null,"MAD","Marokkaanse dirham"]
[null,null,"Guyana","GY",null,null,"MDL","Moldavische leu"]
[null,null,"Haïti","HT",null,null,"MGA","Malagassische ariary"]
[null,null,"Heard en McDonaldeilanden","HM",null,null,"MKD","Macedonische denar"]
[null,null,"Honduras","HN",null,null,"MMK","Myanmarese kyat"]
[null,null,"Hongarije","HU",null,null,"MNT","Mongolische tugrik"]
[null,null,"Hongkong","HK",null,null,"MOP","Macause pataca"]
[null,null,"Ierland","IE",null,null,"MRO","Mauritaanse ouguiya"]
[null,null,"IJsland","IS",null,null,"MUR","Mauritiaanse roepie"]
[null,null,"India","IN",null,null,"MVR","Maldivische rufiyaa"]
[null,null,"Indonesië","ID",null,null,"MWK","Malawische kwacha"]
[null,null,"Irak","IQ",null,null,"MXN","Mexicaanse peso"]
[null,null,"Iran","IR",null,null,"MXV","Mexicaanse Unidad de Inversion (UDI) (Funds code)"]
[null,null,"Israël","IL",null,null,"MYR","Maleisische ringgit"]
[null,null,"Italië","IT",null,null,"MZN","Mozambikaanse metical"]
[null,null,"Ivoorkust","CI",null,null,"NAD","Namibische dollar"]
[null,null,"Jamaica","JM",null,null,"NGN","Nigeriaanse naira"]
[null,null,"Japan","JP",null,null,"NIO","Nicaraguaanse Córdoba Oro"]
[null,null,"Jemen","YE",null,null,"NOK","Noorse kroon"]
[null,null,"Jersey","JE",null,null,"NPR","Nepalese roepie"]
[null,null,"Jordanië","JO",null,null,"NZD","Nieuw-Zeelandse dollar"]
[null,null,"Kaaimaneilanden","KY",null,null,"OMR","Omaanse rial"]
[null,null,"Kaapverdië","CV",null,null,"PAB","Panamese balboa"]
[null,null,"Kameroen","CM",null,null,"PEN","Nieuwe Peruviaanse sol"]
[null,null,"Kazachstan","KZ",null,null,"PGK","Papoease kina"]
[null,null,"Kenia","KE",null,null,"PHP","Filipijnse peso"]
[null,null,"Kirgizië","KG",null,null,"PKR","Pakistaanse roepie"]
[null,null,"Kiribati","KI",null,null,"PLN","Poolse zloty"]
[null,null,"Kleine afgelegen eilanden van de Verenigde Staten","UM",null,null,"PYG","Paraguayaanse guaraní"]
[null,null,"Koeweit","KW",null,null,"QAR","Qatarese rial"]
[null,null,"Kroatië","HR",null,null,"RON","Roemeense leu"]
[null,null,"Laos","LA",null,null,"RSD","Servische dinar"]
[null,null,"Lesotho","LS",null,null,"RUB","Russische roebel"]
[null,null,"Letland","LV",null,null,"RWF","Rwandese frank"]
[null,null,"Libanon","LB",null,null,"SAR","Saoedi-Arabische riyal"]
[null,null,"Liberia","LR",null,null,"SBD","Salomon-dollar"]
[null,null,"Libië","LY",null,null,"SCR","Seychelse roepie"]
[null,null,"Liechtenstein","LI",null,null,"SDG","Soedanees pond"]
[null,null,"Litouwen","LT",null,null,"SEK","Zweedse kroon"]
[null,null,"Luxemburg","LU",null,null,"SGD","Singaporese dollar"]
[null,null,"Macau","MO",null,null,"SHP","Sint-Heleens pond"]
[null,null,"Madagaskar","MG",null,null,"SLL","Sierra Leoonse leone"]
[null,null,"Malawi","MW",null,null,"SOS","Somalische shilling"]
[null,null,"Maldiven","MV",null,null,"SSP","Zuid-Soedanees pond"]
[null,null,"Maleisië","MY",null,null,"SRD","Surinaamse dollar"]
[null,null,"Mali","ML",null,null,"STD","Santomese dobra"]
[null,null,"Malta","MT",null,null,"SYP","Syrisch pond"]
[null,null,"Man","IM",null,null,"SZL","Swazische lilangeni"]
[null,null,"Marokko","MA",null,null,"THB","Thaise baht"]
[null,null,"Marshalleilanden","MH",null,null,"TJS","Tadzjiekse somoni"]
[null,null,"Martinique","MQ",null,null,"TMT","Turkmeense manat"]
[null,null,"Mauritanië","MR",null,null,"TND","Tunesische dinar"]
[null,null,"Mauritius","MU",null,null,"TOP","Tongaanse pa'anga"]
[null,null,"Mayotte","YT",null,null,"TRY","Nieuwe Turkse lira (sinds 1 januari 2005)"]
[null,null,"Mexico","MX",null,null,"TTD","Trinidad en Tobagodollar"]
[null,null,"Micronesia","FM",null,null,"TWD","Nieuwe Taiwanese dollar"]
[null,null,"Moldavië","MD",null,null,"TZS","Tanzaniaanse shilling"]
[null,null,"Monaco","MC",null,null,"UAH","Oekraïense grivna"]
[null,null,"Mongolië","MN",null,null,"UGX","Oegandese shilling"]
[null,null,"Montenegro","ME",null,null,"USD","Amerikaanse dollar"]
[null,null,"Montserrat","MS",null,null,"USN","Amerikaanse dollar (Next day) (aandelen)"]
[null,null,"Mozambique","MZ",null,null,"USS","Amerikaanse dollar (Same day) (aandelen)"]
[null,null,"Myanmar","MM",null,null,"UYU","Uruguayaanse peso"]
[null,null,"Namibië","NA",null,null,"UZS","Oezbeekse sum"]
[null,null,"Nauru","NR",null,null,"VEF","Venezolaanse bolivar"]
[null,null,"Nederland","NL",null,null,"VND","Vietnamese dong"]
[null,null,"Nepal","NP",null,null,"VUV","Vanuatuaanse vatu"]
[null,null,"Nicaragua","NI",null,null,"WST","Samoaanse tala"]
[null,null,"Nieuw-Caledonië","NC",null,null,"XCD","Oost-Caribische dollar"]
[null,null,"Nieuw-Zeeland","NZ",null,null,"YER","Jemenitische rial"]
[null,null,"Niger","NE",null,null,"ZAR","Zuid-Afrikaanse rand"]
[null,null,"Nigeria","NG",null,null,"ZMW","Zambiaanse kwacha"]
[null,null,"Niue","NU"]
[null,null,"Noord -Macedonië","MK"]
[null,null,"Noordelijke Marianen","MP"]
[null,null,"Noord-Korea","KP"]
[null,null,"Noorwegen","NO"]
[null,null,"Norfolk","NF"]
[null,null,"Oeganda","UG"]
[null,null,"Oekraïne","UA"]
[null,null,"Oezbekistan","UZ"]
[null,null,"Oman","OM"]
[null,null,"Oostenrijk","AT"]
[null,null,"Oost-Timor","TL"]
[null,null,"Pakistan","PK"]
[null,null,"Palau","PW"]
[null,null,"Palestina","PS"]
[null,null,"Panama","PA"]
[null,null,"Papoea-Nieuw-Guinea","PG"]
[null,null,"Paraguay","PY"]
[null,null,"Peru","PE"]
[null,null,"Pitcairneilanden","PN"]
[null,null,"Polen","PL"]
[null,null,"Portugal","PT"]
[null,null,"Puerto Rico","PR"]
[null,null,"Qatar","QA"]
[null,null,"Réunion","RE"]
[null,null,"Roemenië","RO"]
[null,null,"Rusland","RU"]
[null,null,"Rwanda","RW"]
[null,null,"Saint-Barthélemy","BL"]
[null,null,"Saint Kitts en Nevis","KN"]
[null,null,"Saint Lucia","LC"]
[null,null,"Saint-Pierre en Miquelon","PM"]
[null,null,"Saint Vincent en de Grenadines","VC"]
[null,null,"Salomonseilanden","SB"]
[null,null,"Samoa","WS"]
[null,null,"San Marino","SM"]
[null,null,"Saoedi-Arabië","SA"]
[null,null,"Sao Tomé en Principe","ST"]
[null,null,"Senegal","SN"]
[null,null,"Servië","RS"]
[null,null,"Seychellen","SC"]
[null,null,"Sierra Leone","SL"]
[null,null,"Singapore","SG"]
[null,null,"Sint-Helena, Ascension en Tristan da Cunha","SH"]
[null,null,"Sint-Maarten","MF"]
[null,null,"Sint Maarten","SX"]
[null,null,"Slovenië","SI"]
[null,null,"Slowakije","SK"]
[null,null,"Soedan","SD"]
[null,null,"Somalië","SO"]
[null,null,"Spanje","ES"]
[null,null,"Spitsbergen en Jan Mayen","SJ"]
[null,null,"Sri Lanka","LK"]
[null,null,"Suriname","SR"]
[null,null,"Syrië","SY"]
[null,null,"Tadzjikistan","TJ"]
[null,null,"Taiwan","TW"]
[null,null,"Tanzania","TZ"]
[null,null,"Thailand","TH"]
[null,null,"Togo","TG"]
[null,null,"Tokelau","TK"]
[null,null,"Tonga","TO"]
[null,null,"Trinidad en Tobago","TT"]
[null,null,"Tsjaad","TD"]
[null,null,"Tsjechië","CZ"]
[null,null,"Tunesië","TN"]
[null,null,"Turkije","TR"]
[null,null,"Turkmenistan","TM"]
[null,null,"Turks- en Caicoseilanden","TC"]
[null,null,"Tuvalu","TV"]
[null,null,"Uruguay","UY"]
[null,null,"Vanuatu","VU"]
[null,null,"Vaticaanstad","VA"]
[null,null,"Venezuela","VE"]
[null,null,"Verenigde Arabische Emiraten","AE"]
[null,null,"Verenigde Staten","US"]
[null,null,"Verenigd Koninkrijk","GB"]
[null,null,"Vietnam","VN"]
[null,null,"Wallis en Futuna","WF"]
[null,null,"Westelijke Sahara","EH"]
[null,null,"Wit-Rusland","BY"]
[null,null,"Zambia","ZM"]
[null,null,"Zimbabwe","ZW"]
[null,null,"Zuid-Afrika","ZA"]
[null,null,"Zuid-Georgia en de Zuidelijke Sandwicheilanden","GS"]
[null,null,"Zuid-Korea","KR"]
[null,null,"Zuid-Soedan","SS"]
[null,null,"Zweden","SE"]
[null,null,"Zwitserland","CH"]

{"sheet":"Schema A3","index":2,"n_rows":36,"n_cols":12,"rows_kept":36,"cut":false,"hidden":true,"merged":[]}
[null,null,"DIT SCHEMA IS NIET IN GEBRUIK VOOR VALIDATIE  - alleen om een overzicht te maken"]
[]
[null,null,"RulingCategory","ETR601 [OECD and EU] - Relating to preferential regime (en eventueel de toevoeging'(tonnage)' of '(innovation)'","ETR602 [OECD and EU] -  Unilateral APA or other TP ruling","ETR603 [EU-ONLY] - Bilateral or multilateral APA (ONLY to be used for exchanges under the EU framework)","ETR604 [EU-ONLY] - Exchange of summary information on request for bilateral or multilateral APA (ONLY to be used for exchanges under the EU framework)","ETR605 [OECD and EU] - Downward adjustment ruling","ETR606 [OECD and EU] - PE ruling","ETR607 [OECD and EU] - Conduit ruling","ETR608 [EU-ONLY] - Hybrid entity ruling (ONLY to be used for exchanges under the EU framework)","ETR609 [EU-ONLY] - Other"]
[]
[null,null,"RulingTypeInfo",null,null,null,null,null,null,null,null,"Participation exemption / parent-subsidiary directive"]
[null,null,null,null,null,null,null,null,null,null,null,"Dividend withholding tax / other withholding tax"]
[null,null,null,null,null,null,null,null,null,null,null,"Foreign tax liability / tax residency"]
[null,null,null,null,null,null,null,null,null,null,null,"Determination (non)transparency"]
[null,null,null,null,null,null,null,null,null,null,null,"Tax treatment hybrid loan"]
[null,null,null,null,null,null,null,null,null,null,null,"Attribution of shares to permanent establishment"]
[null,null,null,null,null,null,null,null,null,null,null,"business restructurings / reorganization of company structure"]
[null,null,null,null,null,null,null,null,null,null,null,"Tax deductible costs / tax deductibility of expenditures (including financial expenses)"]
[null,null,null,null,null,null,null,null,null,null,null,"Exit taxation"]
[null,null,null,null,null,null,null,null,null,null,null,"Ruling/APA regarding tax anti-avoidance measures of the Member State, including the GAAR"]
[]
[null,null,"Summary 1","1. 1-IVA / Afpelmethode \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the residual profit of ##NAME SHORT##, which can be allocated to this qualifying IP, is taxed under the Innovation Box regime The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[BTL routine/Sales] \nThe related party with whom the Taxpayer entered into the transaction covered by the ruling performs routine sales activities for the Taxpayer. These activities are remunerated by a TNMM with pli ROS (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Vaste inrichting [fixed place of business] \nThe activities of Taxpayer in the Netherlands constitute a permanent establishment for the Dutch Corporate Income Tax Act 1969 and the tax treaty that may apply.",null,"Kwalificatie rechtsvorm belastingplichtige [determination (non)transparency taxpayer] \nDetermination of the qualification of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer.","Deelnemingsvrijstelling [participation exemption] \nThe participation exemption (article 13 of the Dutch Corporate Income Tax Act 1969) is applicable to income (e.g. dividend and capital results) derived from the subsidiary of Taxpayer. The subsidiary is not held as a portfolio investment / should be considered a qualifying portfolio investment company (based on the asset test and/or subject-to-tax test) and therefore the participation exemption is applicable."]
[null,null,"Summary 2","2. Cost+ \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the profit (calculated as a mark-up on the direct and indirect R&D costs) of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime. The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[BTL routine/Manufacturing] \nThe related party with whom the Taxpayer entered into the transaction covered by the ruling performs routine manufacturing  choose: contract / tolling) activities for the Taxpayer. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Negatieve v.i. [no fixed place of business] \nThe foreign taxpayer does not have a fixed place of business in the Netherlands, therefore there is no permanent establishment in the Netherlands. There is also no independent agent in the Netherlands.",null,"Kwalificatie rechtsvorm moedermaatschappij [determination (non)transparency parent] \nDetermination of the qualification of the immediate parent of Taxpayer as a transparent / non- transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer.","Dividendbelasting [dividend withholding tax] \nIn accordance with the Dutch Dividend Withholding Tax Act 1965 no Dutch dividend withholding tax is due on dividend distributions by Taxpayer. It was also established that there was no abuse of law. In accordance with the Dividend Withholding Tax Act 1965 Taxpayer must declare within one month after the moment the proceeds were made available that all conditions of the Dutch Dividend Withholding Tax Act 1965 are met. \n"]
[null,null,"Summary 3","3. Royaltybenadering \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the net royalty income of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime.  The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[BTL routine/Other] \nThe related party with whom the Taxpayer entered into the transaction covered by the ruling performs routine services (choose: sales support / purchasing / contract R&D / headquarters / other) activities for the Taxpayer. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Negatieve v.i. [prepartory/auxiliary character] \nThe foreign taxpayer does  have a fixed place of business in the Netherlands, but the overall activity of the fixed place of business is of a preparatory or auxiliary character. Therefore there is no permanent establishment in the Netherlands. There is also no independent agent in the Netherlands.",null,"Kwalificatie rechtsvorm deelneming [determination (non)transparency subsidiary] \nDetermination of the qualification of the direct subsidiary of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer.","Dividendbelasting houdstercoöperatie [dividend withholding tax holding cooperative] \nTaxpayer qualifies as a 'holding cooperative' and is in principle subject to Dutch dividend withholding tax (15%). A cooperative that is not sufficiently actively involved in the management of its investments and that has sufficient (qualitative and quantitative) presence in the Netherlands (such as personnel and an office) qualifies as a 'holding cooperative'.\n"]
[null,null,"Summary 4","4. Other \n\"Innovation Box Ruling (art. 12b CITA) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. It has a R&D facility in ##CITY## (NL), employing approx. ### FTE. These R&D activities result in intellectual property with regard to ##MAIN ACTIVITY##. As such, the ownership of this IP resides in ##NAME SHORT##. The benefits of this IP qualify for the Innovation Box. \nBased on an analysis of the functions performed, part of the profit of ##NAME SHORT##, which can be allocated to the qualifying IP, is taxed under the Innovation Box regime. This part of the profit is calculated according to the following method: ##BRIEF DESCRIPTION METHOD (NOT BEING 1 – 4)##. The remaining profit is taxed at the regular statutory rate. [In case of small taxpayer (art.12ba, 1, b CITA): The qualifying IP may contain third category IP assets.] Please note that the Innovation Box regime is BEPS 5 compliant.”","[NL routine/Sales] \nThe Taxpayer performs routine sales activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli ROS (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,"Negatieve v.i. [no fixed place of business/home-office] \nThe foreign taxpayer (the employer of (an) individual(s)) does not have a fixed place of business in the Netherlands, because the home office of the employee(s) is not at the disposal of the employer. Therefore there is no permanent establishment in the Netherlands. There is also no independent agent in the Netherlands.",null,null,"Dividendbelasting niet houdstercoöperatie [dividend withholding tax non-holding cooperative] \nTaxpayer qualifies as a 'non-holding cooperative' and is not subject to Dutch dividend withholding tax. A cooperative that is sufficiently actively involved in the management of its investments and that has sufficient (qualitative and quantitative) presence in the Netherlands (such as personnel and an office) qualifies as a 'non-holding cooperative'.\n"]
[null,null,"Summary 5","5. Vennootschap met standaard tonnageruling \n\"Tonnage Tax  Ruling (art. 3.22-3.24 Income Tax Code) ##NAME FULL##  is a Shipping company, focusing on ##MAIN ACTIVITY##, with offices in ##CITY## (NL), employing approx. ### FTE. These activities regard the strategic / commercial  / technical / crewing management with regard to ##NUMBER## seagoing vessels.  The benefits of the exploitation of these seagoing vessels qualify for the Tonnage Tax to the extent that these benefits relate to transportation activities. As a result the qualifing profits are taxed on the basis of the net tonnage of the ships being exploited by the company.”\n","[NL routine/Subprincipaal] \nThe Taxpayer performs routine sales activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli ROS (...%) which is within the interquartile range which ranges from (...%) until (...%). The difference between the actual result and the remuneration as agreed upon is deductible for corporate income tax purposes.",null,null,null,"Beloning vaste inrichting [renumeration fixed place of business] \nThe activities of the permanent establishment of Taxpayer are remunerated on an at arm’s length basis.",null,null,"Dividendbelasting [dividend withholding tax] \nDetermination of the applicable rate XX%* of Dutch dividend withholding tax on dividend distributions by Taxpayer in accordance with the tax treaty between the Netherlands and the country of residence of the immediate parent of Taxpayer. The immediate taxpayer holds an interest of XX%* in Taxpayer."]
[null,null,"Summary 6","6. Vennootschap met tonnageruling met winstsplitsingsafspraken \n\"Tonnage tax ruling (art. 3.22 IncomeTaxAct) ##NAME FULL## (“##NAME SHORT##”) is a ##TYPOLOGY## company, focusing on ##MAIN ACTIVITY##. The place of effective management of the company is in ##CITY## (NL), employing approx. ### FTE. The profits of the company from the operation of ships for the transport of goods and persons qualify for a taxation according to the tonnage tax regulations. These activities regard the strategic / commercial  / technical / crewing management with regard to ##NUMBER## seagoing vessels. The other profits from the operation of ships – being profits from activities other than the transport of goods and persons – are taxed according to the general rules  of the Income Tax Act.\nAs a result the shipping profits of ##NAME SHORT## are taxed on the basis of the net tonnage of the ships being exploited by the company. According to the tonnage tax ruling ###% of the total profits are taxed on a tonnage tax basis. The other profits from the operation of ships – amounting to ###% of the total profits - are taxed according to the general rules  of the Income Tax Act.”","[NL routine/Manufacturing] \nThe Taxpayer performs routine manufacturing (choose: contract / tolling) activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,null,null,null,"Vangnetbepaling [application tax treaty] \nThe Taxpayer has been granted the benefits of the Country* – Netherlands tax treaty. Obtaining the benefits of that tax treaty has not been one of the principal purposes in the establishment, acquisition or maintenance of the TaxPayer or the conduct of its operations."]
[null,null,"Summary 7",null,"[NL routine/Other] \nThe Taxpayer performs routine services (choose: sales support / purchasing / contract R&D / headquarters / other) activities for the related party with whom the Taxpayer entered into the transaction covered by the ruling. These activities are remunerated by a TNMM with pli costs (...%) which is within the interquartile range which ranges from (...%) until (...%).",null,null,null,null,null,null,"Buitenlandse belastingplicht [foreign tax liability parent] \nThe immediate parent(s) of Taxpayer is/are not liable to Dutch corporate income  tax (articles 17 and 17a of the Dutch Corporate Income Tax Act 1969) for income derived  from a substantial shareholding/membership rights. Articles 17 and 17a of the Dutch Corporate Income Tax Act 1969 can be regarded as anti-abuse provisions. In this specific case there is no abuse of law."]
[null,null,"Summary 8",null,"[DVL-financing] \nThe Taxpayer provides financing activities for group companies. The Taxpayer receives a gross remuneration for these services amounting to ... bps over the outstanding loans.",null,null,null,null,null,null,"Buitenlandse belastingplicht bel.pl. [foreign tax liability taxpayer]\nTaxpayer (the immediate parent of the Dutch company) is not liable to Dutch corporate income tax (articles 17 and 17a of the Dutch Corporate Income Tax Act 1969) for income derived  from a substantial shareholding/membership rights. Articles 17 and 17a of the Dutch Corporate Income Tax Act 1969 can be regarded as anti-abuse provisions. In this specific case there is no abuse of law."]
[null,null,"Summary 9",null,"[DVL-royalties] \nThe Taxpayer provides licensing activities for group companies. The Taxpayer receives a gross remuneration for these services amounting to ... bps over the incoming royalties.",null,null,null,null,null,null,"Hybride financiering [tax treatment hybrid loan-1]\nDue to the loan conditions, the loan from Taxpayer qualifies for tax purposes as equity. As a result, the participation exemption (article 13 of the Dutch Corporate Income Tax Act 1969) will be applicable on income derived from this loan. In short: (i) the term of the loan is longer than 50 years or the loan has no maturity date, (ii) the interest is profit depending and (iii) the loan is subordinated to all other creditors and is only due and payable by bankruptcy, suspension of payment or liquidation.\n"]
[null,null,"Summary 10",null,"[Profit Split] \nDue to the interrelated nature of (i) the functions performed (including the attribution of assets and risks) of the Taxpayer and the related party with whom the Taxpayer entered into the transaction covered by the ruling and (ii) the contributions made by both parties, it is agreed that the result (residual profit or loss) will be split between the related party (... %) and Taxpayer (...%).",null,null,null,null,null,null,"Hybride financiering [tax treatment hybrid loan -2]\nDue to the loan conditions the loan to Taxpayer qualifies for tax purposes as equity. In short: (i) the term of the loan is longer than 50 years or the loan has no maturity date, (ii) the interest is profit depending and (iii) the loan is subordinated to all other creditors and is only due and payable by bankruptcy, suspension of payment or liquidation.\n"]
[null,null,"Summary 11",null,"Other \n(for example: infokap/winstallocatie vi/afwijkende pli).",null,null,null,null,null,null,"Toerekening aandelen aan vaste inrichting [attribution of shares to permanent establishment] \nThe shares of the direct subsidiary of taxpayer are attributable to a permanent establishment of Taxpayer in the Netherlands.\n"]
[null,null,"Summary 12",null,null,null,null,null,null,null,null,"Kwalificatie rechtsvorm belastingplichtige [determination (non)transparency taxpayer] \nDetermination of the qualification of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer."]
[null,null,"Summary 13",null,null,null,null,null,null,null,null,"Kwalificatie rechtsvorm moedermaatschappij [determination (non)transparency parent] \nDetermination of the qualification of the immediate parent of Taxpayer as a transparent / non- transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer."]
[null,null,"Summary 14",null,null,null,null,null,null,null,null,"Kwalificatie rechtsvorm deelneming [determination (non)transparency subsidiary] \nDetermination of the qualification of the direct subsidiary of Taxpayer as a transparent / non-transparent* entity for Dutch  tax purposes.\nIndien en voor zover relevant: This means that from a Dutch tax perspective the payments by the Dutch company are considered to flow through (to) (directly to the participants of) Taxpayer."]
[null,null,"Summary 15",null,null,null,null,null,null,null,null,"Overige rulings m.b.t. pensioenvrijstelling [Other rulings - Pension exemption] \n##NAME FULL## is comparable to a Dutch pension fund and therefore exempt from Dutch corporate income tax as a foreign taxpayer."]
[null,null,"Summary 16",null,null,null,null,null,null,null,null,"Overige rulings m.b.t. renteaftrekbeperkingen (10a) [Other rulings - interest deduction limitation] \nThe intercompany loan between ##NAME FULL## and ##NAME FULL## falls within the scope of the Dutch anti-base erosion rules. However, ##NAME FULL## can successfully invoke a counter-evidence rule. As a result, the interest is not restricted in deduction under the Dutch anti-base erosion rules."]
[null,null,"Summary 17",null,null,null,null,null,null,null,null,"Overige rulings m.b.t. vestigingsplaats en de vestigingsplaatsfictie [Other rulings - place of residence and residence fiction] \n......."]
[null,null,"Summary 18",null,null,null,null,null,null,null,null,"Overige rulings m.b.t. grensoverschrijdende fusie [Other rulings -crossborder merger] \nConfirmation of the Dutch corporate income tax and/or Dutch dividend tax treatment with regard to the cross-border merger of ##NAME FULL## into ##NAME FULL##."]
[null,null,"Summary 19",null,null,null,null,null,null,null,null,"ATAD2  \nHybrid entity mismatch rules (ATAD2) do not apply to payments made by ##NAME FULL NL entity## to ##NAME FULL Foreign company##."]
[null,null,"Summary 20",null,null,null,null,null,null,null,null,"Conditionele bronbelasting op dividenden [(conditional) withholding tax on dividends] \nIn accordance with the Withholding Tax Act 2021 no Dutch withholding tax is due on dividend payments by Taxpayer to its member as from 1 January 2024. In this specific case there is no abuse of law."]
[null,null,"Summary 21",null,null,null,null,null,null,null,null,"Artikel 8ba-8bd Wet Vpb [Article 8ba-8bd CITA] \nA capital contribution of cash into the Taxpayer does not lead to corporate income tax being due in the Netherlands as there is no value difference to which the anti-transfer pricing mismatches rules (Articles 8ba-8bd of the Corporate Income Tax Act) apply. Article 8bd Dutch Corporate Income Tax Act 1969 in principle targets mismatches that could arise due to valuation differences on the transfer of assets through acts such as capital contributions, dividend distributions and liquidation distributions and comparable. In short, the article stipulates that when a Dutch taxpayer acquires an asset from an associated entity by way of acts such as a capital contribution, the Dutch taxpayer is obliged to record the acquired asset in its Dutch tax base for the value taken into account in a profit tax by the contributing/distributing entity."]

{"sheet":"Configuratie","index":3,"n_rows":8,"n_cols":2,"rows_kept":8,"cut":false,"hidden":true,"merged":[]}
["Het werkblad 'Configuratie' bevat enkele vaste visual basic gegevens die soms gewijzigd moeten worden."]
[]
["Omschrijving","Waarde"]
["Xml namespace Belastingdienst bij prefix \"etrbd\"","urn:bd:rav:etrbd:v1"]
["Xml namespace OECD bij prefix \"etr\"","urn:oecd:ties:etr:v1"]
["XSD bestandsnaam Belastingdienst","Etr_Belastingdienst_Inkomend_v1.0.xsd"]
["E-mail adres Belastingdienst","exchange-tax-rulings@belastingdienst.nl"]
["applicatieversie","6.2"]