The Dutch Ministry of Finance has announced that from 1 July 2019, stricter requirements will be put in place for the issuance of advance tax rulings with an international character. In particular, tax rulings will not be granted with respect to international structures/transactions where the only motive is to reduce Dutch or foreign tax due. Further, stricter requirements will be applied in relation to physical presence in the Netherlands when an application for a ruling is evaluated, including in terms of whether the number of employees properly reflects the size of the company and the activities carried out in the...