Risk Assessment

Does your company need ATAD2 documentation?

Answer 8 quick questions about your group structure to get an instant risk assessment. Takes about 2 minutes.

Question 1 of 812%
Question 1

Is your company part of a group with entities in more than one country?

This includes parent companies, subsidiaries, branches, and partnerships in other jurisdictions.

Yes, we have entities in multiple countries
No, all entities are in the Netherlands only
Not sure
Question 2

Does any group entity hold 25% or more in another entity across borders?

This includes voting rights, capital interest, or profit entitlement. The ATAD2 "association" test uses a 25% threshold (50% for reverse hybrids).

Yes, 25% or more cross-border ownership exists
No, all cross-border holdings are below 25%
Not sure
Question 3

Are there intercompany payments between Dutch and foreign group entities?

Think of interest on intercompany loans, royalties, management fees, service fees, cost-sharing payments, or dividends.

Yes, there are cross-border intercompany payments
No intercompany payments exist
Not sure
Question 4

Does your structure include hybrid entities or hybrid financial instruments?

A hybrid entity is one classified differently for tax purposes in different countries (e.g., transparent in NL, opaque abroad). A hybrid instrument is treated as debt in one country and equity in another.

Yes, we have hybrid entities or instruments
No, all entities and instruments are classified consistently
Not sure
Question 5

Does your group include Dutch partnerships (CV or VOF) with foreign investors?

Dutch limited partnerships (CV) are often transparent in NL but may be treated as opaque by foreign investors' jurisdictions, creating reverse hybrid risk.

Yes, we have Dutch CVs/VOFs with foreign participants
No
Not sure
Question 6

Does any group entity have a permanent establishment (PE) abroad?

A PE could be a branch, fixed place of business, or dependent agent in another country.

Yes, there are PEs in the structure
No PEs
Not sure
Question 7

Do you currently have ATAD2 documentation in place?

This would be a formal analysis mapping your cross-border arrangements against Articles 12aa-12ag.

Yes, we have current documentation
Yes, but it may be outdated (pre-2025)
No, we have no ATAD2 documentation
Question 8

Has your group structure changed in the past 12 months?

New acquisitions, disposals, restructurings, new intercompany agreements, or changes in entity classification.

Yes, significant changes occurred
Minor changes only
No, structure is unchanged

Key findings from your assessment

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This Risk Check is an automated indication, not tax advice. It does not create an advisor relationship.