Netherlands: Mutual agreement procedure (MAP) annual report for 2025
Highlights a 97% resolution rate for tax disputes, the benefits of prefiling meetings, and interest mitigation options.
The recently published Dutch mutual agreement procedure (MAP) annual report for 2025 provides insights into how the Netherlands supports the resolution of international tax disputes and the elimination of double taxation.
According to the report, 97% of MAP cases in the Netherlands were successfully resolved. A factor that may contribute to this outcome is the availability of prefiling meetings. Before formally submitting a MAP, bilateral advance pricing agreement (BAPA), or multilateral advance pricing agreement (MAPA) request, taxpayers may engage in an informal and nonbinding discussion with the Dutch tax authorities. Such discussions can provide greater clarity on procedural aspects and help assess whether a request is likely to be suitable and effective in the relevant circumstances.
The report also notes that, in a MAP context, taxpayers may request mitigation of tax interest or collection interest charged in the Netherlands. This possibility is generally not available in BAPA or MAPA cases.
The top five jurisdictions with which the Netherlands had the highest number of MAP cases in 2025 are Belgium, Germany, France, the United Kingdom, and the United States.
Read a July 2026 report prepared by the KPMG member firm in the Netherlands