New approach to HTM


The 2020 Annual Plan of the Dutch tax authorities states that the changes will improve compliance with tax rules. The new approach follows the review of HTM. The following large companies are distinguished in the new HTM approach:

  • One hundred largest companies
    The current HTM agreements concluded by the Dutch tax authorities with the hundred largest and most complex companies will be terminated. An individual tax monitoring plan will replace these HTM agreements.
  • Medium-sized companies according to Dutch accounting law
    The medium-sized companies according to Dutch accounting law can conclude an HTM agreement under stricter requirements and for a limited duration of three years.
  • Other large companies
    The other large companies can only participate in HTM through their tax adviser. Companies that already have an HTM-agreement in place, will be assessed as to whether and how they qualify for HTM via their tax adviser.
Consequences for your company

The tax authorities will discuss the exact changes of HTM with companies in the coming period. The changes will in most cases lead to stricter requirements for HTM. In The involvement of external tax advisors will be taken into account.

In need of assistance?

Loyens & Loeff has a Tax Assurance team. Our experts have extensive experience in entering into, applying and improving HTM. As well as in controlling of and observing applicable tax rules.

Our experts will guide you in setting up, testing and improving your Tax Control Framework (‘TCF’). A TCF contains a company’s fiscal processes, risks and mitigation measures (controls. A TCF is not restricted to HTM situations and is therefore recommended for every company.

Our approach

Our vision is that a TCF never stands on its own and is a vital part of the Business Control Framework of your company. Our approach is characterized by the focus on your organization, (tax) strategy and policy. Your organization, your systems and your risk profile determine which risks are (un) acceptable and therefore the best way of detecting and controlling your company’s tax risks.

Due to our customized approach, you are not only ’in control’ for tax purposes. You are certain about your tax position in an increasingly challenging tax landscape as well.

Your choice for Loyens & Loeff

Full service tax and law firm

Loyens & Loeff is a leading full service tax and law firm. We have experts in all tax and legal disciplines. Our full tax service approach makes it possible to implement all taxes and duties in your TCF. Together with our legal experts we can also set up your Corporate Governance and Legal Control Framework and integrate them into your Business Control Framework.

Independent advisor

In the constantly changing tax environment, continuity in tax support is important. Our continuity is guaranteed by our independent position as a tax and legal service provider. Our independence also enables us to work together with the partners that best suit you.


If you have any questions about the above, please do not hesitate to contact your contact person at Loyens & Loeff or one of our Tax Assurance experts.