Does your company need ATAD2 documentation?
Answer 8 quick questions about your group structure to get an instant risk assessment. Takes about 2 minutes.
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.
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).
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.
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.
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.
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.
Do you currently have ATAD2 documentation in place?
This would be a formal analysis mapping your cross-border arrangements against Articles 12aa-12ag.
Has your group structure changed in the past 12 months?
New acquisitions, disposals, restructurings, new intercompany agreements, or changes in entity classification.
Key findings from your assessment
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