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Generated analysis per arrangement
One automatically generated analysis per intercompany payment, with article-level conclusions referenced to the statute.
Automated ATAD2 Documentation
Generate your ATAD2 documentation file. In minutes, not weeks.
An analysis memo plus compliance checklist for your CIT file, generated automatically and ready to download in about 15 minutes. Standard file €49 excl. VAT. Start with the free Risk Check: no payment, no account. 14-day money-back promise.
Lowkey Automation · KvK 42057580 · EU-based processing
§ 01 · What you get
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Compliance checklist for your CIT file
One-page summary of every required ATAD2 element, mapped to where it sits in the memo. Ready for retention.
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Built to the Art. 12ag standard
Sub-paragraph-level citations, an evidence inventory per arrangement, and the Art. 12ag documentation statement, kept in your own administration.
Two ways to start
From a free check to a complete documentation file
Start with the free Risk Check, generate the file you need, and regenerate it each year. Every output is documentation you keep in your own administration.
Free Risk Check
A guided questionnaire that gives you an automated read on whether ATAD2 is likely to apply, plus an emailed PDF summary. No payment, no account.
Start the Risk CheckDocumentation File
The tool generates your full hybrid mismatch analysis from the answers you provide, with an analysis memo and a compliance checklist for your administration.
See pricing
The Five Mismatches
Which hybrid mismatches does ATAD2 address?
Articles 12aa through 12ag of the Dutch Corporate Income Tax Act target five distinct categories of cross-border hybrid mismatches.
Deduction / No Inclusion
Art. 12aa sub a / b Dutch CIT Act
A payment is deducted by the payer but not included in the taxable income of the recipient. The most common mismatch type.
Double Deduction
Art. 12aa sub g Dutch CIT Act
The same expense is deducted in two jurisdictions simultaneously, creating a double tax benefit. Relief under Art. 12af when dual inclusion income arises.
Imported Mismatch
Art. 12ad Dutch CIT Act
A mismatch outcome in another jurisdiction is shifted to the Netherlands through a series of connected arrangements.
Reverse Hybrid
Art. 12ae Dutch CIT Act
A Dutch entity treated as transparent domestically but opaque abroad, causing income to fall through the cracks. Effective since 1 January 2022.
PE Mismatches
Art. 12aa sub c / d / f Dutch CIT Act
Income attributed to a permanent establishment is not taxed in either the head office or PE jurisdiction, or deductions are taken without corresponding inclusion.
How It Works
From questionnaire to documentation file in four steps
A structured workflow so nothing is missed and the generated file is built to the Art. 12ag standard.
1
Free Risk Check
Answer a short guided questionnaire about your group structure. The tool gives you an instant read on whether ATAD2 is likely to apply.
2
Intake & Scoping
Provide your intercompany arrangements and entity classifications. The tool confirms which documentation file fits your structure.
3
Generation
The tool generates a full ATAD2 file with legal analysis against each mismatch category and a one-page compliance checklist per entity.
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Delivery
You receive editable Word and PDF documents to keep in your CIT file. Regenerate the file each year as your structure evolves.
Who Is This For
Built for both in-house teams and advisors
Use the tool to document your own structure, or to produce ATAD2 files for the clients you advise.
CFOs & In-House Tax Teams
You know your structure, but documenting the ATAD2 analysis is detailed and time-consuming. The tool generates the file for you.
- A documentation file built to the Art. 12ag standard
- A free Risk Check on your current structure
- Regenerate the file each year as your group evolves
Tax Advisors & Accountants
Produce your clients' ATAD2 files faster. The tool does the structured analysis, and you keep the output under your own engagement.
- Structured intake questionnaires for each client
- A generated file you review and sign off yourself
- A repeatable process across multiple clients
Don't wait for the tax authorities to ask
Contemporaneous ATAD2 documentation helps support your deductions and the normal burden of proof. Start with a free Risk Check.
Start free Risk Check