The Dutch tax administration has 26 so-called “knowledge groups” dealing with specific complex technical tax issues in their assigned areas. The positions expressed by the knowledge groups in so-called position papers serve as guidelines for tax auditors in their dealings with taxpayer files and taxpayer issues. The tax administration has hitherto resisted calls to disclose the position papers elaborated by its knowledge groups, even though such disclosure would contribute to improved legal certainty and less litigation.
As of 30 March 2023, however, the tax authorities reversed their earlier refusal and started the publication of the positions drafted by the knowledge groups through a dedicated website [in Dutch]. Since then, the position papers drafted from 2022 onward can be accessed on the site and cover a wide range of tax areas, including Dutch corporate income tax (53 positions), international tax matters (11 positions), dividend withholding tax (32 positions), or VAT (17 positions). Earlier position papers are expected to be added in due time and the site is expected to be kept updated by the addition of new position papers.