Pricing

Fixed-Fee ATAD2 Documentation, Generated for You

A self-service tool that produces your ATAD2 documentation file from a structured questionnaire. Start with a free risk check, then generate the file for a flat fee. This is software you use to prepare your own documentation, not tax advice.

Risk Check
Know where you stand
Free
no payment, no account
Best for: A first read on whether ATAD2 is likely to apply to your structure
Result: instant, on screen
  • Guided questionnaire
  • Automated risk indication across all 5 mismatch categories
  • Emailed PDF summary with legal references (Art. 12aa–12ag)
  • Tells you which documentation file you likely need
  • No obligation to continue
Start free Risk Check
Complex Documentation File
For multi-entity groups
from €995
excl. 21% VAT, scope-based
Best for: Groups with several entities or an actual hybrid mismatch
Delivery: 3–5 business days
  • Everything in the Standard file
  • Multi-entity analysis (4+ entities)
  • Hybrid instrument quantification workbook
  • Imported mismatch chain analysis
  • Reverse hybrid assessment under 2025 rules
  • Per-entity summaries
  • Flags genuinely complex cases to take to an advisor
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HybridMismatch is an automated documentation tool. It generates a file you keep in your own administration to support the position in your corporate income tax return. It is not tax advice and does not create an advisor relationship. You remain responsible for the positions you file. For genuinely complex structures, have the output reviewed by a qualified tax advisor.

Additional Options

Ongoing support and volume pricing

Keep your documentation current year after year, or engage us for multiple entities at scale.

Annual Update

€245 per year

The Art. 12ag documentation obligation is annual. Each year you regenerate the file to reflect new intercompany arrangements, restructurings, and legislative developments, including the January 2025 entity classification reform. Your documentation stays current for the next return.

Set up annual update

Volume & Enterprise

Custom pricing

Advisory firms managing multiple client engagements and large corporate groups with many entities benefit from volume pricing. We offer structured collaboration, a simpler intake process, and dedicated support for larger engagements. Lowkey's advisor portal also covers 30%-regeling and fiscale eenheid VPB automation for firms that handle multiple Dutch tax procedures.

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Pricing FAQ

Common questions about our pricing

Everything you need to know before getting started.

Are prices inclusive of VAT?

No. All prices listed are exclusive of 21% Dutch VAT. VAT will be added on the invoice. For B2B clients within the EU with a valid VAT number, the reverse-charge mechanism may apply - we will handle this automatically based on your billing details.

When do I pay?

The Risk Check is free. For a documentation file, you complete the intake questionnaire, receive a scope confirmation, and then a secure Stripe payment link. Payment is due before the file is generated. For Complex files, the exact fee is confirmed with you before payment.

What if ATAD2 doesn't apply to my company?

That is the most common outcome, and the file is still worth having. You get generated documentation showing that ATAD2 does not apply to your structure, which is what the Dutch tax authorities expect to see. Without it, the burden of proof can shift to you during an audit.

Is this tax advice?

No. HybridMismatch is an automated tool that generates documentation from the answers you provide. It does not give tax advice and does not create an advisor relationship. You remain responsible for the positions in your corporate income tax return. If your structure is genuinely complex, have the generated file reviewed by a qualified tax advisor before you rely on it.

Do you provide audit defense?

No. The tool generates a documentation file you keep in your administration to satisfy the Art. 12ag obligation. It does not include legal representation, and we do not appear on your behalf during audits or court proceedings. If the tax authorities challenge your position, your own tax advisor or counsel uses the file as the basis for the response.

Why fixed fees and not hourly?

Because ATAD2 documentation is a scoped, repeatable output, not open-ended advisory. Hourly billing rewards inefficiency and exposes you to runaway bills the day your structure turns out to be more interesting than expected. A fixed fee per tier means the price is set before you buy, with no surprise hours. If your structure turns out to be genuinely outside the tier scope, we agree a revised fee in writing before continuing.

Do you work directly with end-clients, or only through tax advisors?

Both. In-house tax and finance teams use the tool directly for full ATAD2 documentation, screening, and annual updates. Tax advisors and accountants use it to generate the file and white-label the output into their own engagement; the advisory relationship with the end client stays theirs, not ours. Either route is fine. The intake form lets you indicate which one applies; the deliverable is identical.

What if the Dutch tax authorities challenge our ATAD2 position?

A file prepared to the standard set by Art. 12ag of the Dutch Corporate Income Tax Act helps satisfy the documentation obligation and support the normal burden of proof, so your tax advisor or counsel has a basis to defend the return position. The tool generates the memo and the supporting analysis. It does not litigate or appear on your behalf, and the protection only holds if the file reflects your actual facts, so check the output against your situation before you rely on it.

How do I know which tier I need?

Start with the free Risk Check. It takes two minutes and gives you an initial indication of your ATAD2 exposure, then points you to the file you likely need. Most straightforward structures need the Standard file; groups with several entities or an actual mismatch need the Complex file. The Risk Check costs nothing, so there is no risk in starting there.

Ready to document your ATAD2 position?

Start with a free Risk Check or jump straight to an engagement. Fixed fees, no surprises, a documented file for your administration.

Get Started