The Netherlands Ministry of Finance, on June 12, published five decrees updating guidance on advance pricing agreements (APAs), advance tax rulings (ATRs), and minimum substance requirements to obtain an APA or ATR, according to a report by Loyens & Loeff. Minimum substance requirements are also provided for service companies that do not have an APA that wish to apply the Dutch treaty network or the EU Interest & Royalty Directive. For details and analysis, see a June 12 report by Loyens & Loeff
