A letter from Dutch State Secretary for Finance Eric Wiebes to the Dutch House of Representatives has been published concerning the Dutch practice for advanced pricing agreements (APA) and advance tax rulings (ATR). The letter provides an overview of APA/ATR team's approach as well as specific areas for which advance certainty may currently be provided, including: Application of the participation exemption for intermediate holding companies in international structures and for top holding companies; International structures involving hybrid forms of financing or hybrid entities (hybrid mismatches); Existence of a permanent establishment in the Netherlands or in the BES-islands; Application of Section...