On 12 June 2014, five Decrees were published by the Dutch Underminister of Finance replacing the current 2004 Decrees on Advance Pricing Agreements (“APA”), Advance Tax Rulings (“ATR”) and “Substance Requirements”.
Although the Decrees have affect as per 13 June 2014, the day after publication, the Dutch ruling practice already applied some of the elements as per 1 January 2014.