Will keeping your dutch bank account become dependent on your tax structuring?

Dutch central bank publishes good practices for banks to identify tax integrity risks with customers

1. Introduction

Early July 2019, the Dutch Central Bank (DCB) published a good practices document for banks regarding the identification of ‘tax integrity risks’ with customers (Good Practices). The Good Practices should assist banks in their risk management vis-à-vis tax evasion and tax avoidance, ultimately safeguarding their sound and controlled business operations.

While the Good Practices are – formally – not legally binding and are only intended to give guidance how to interpret and apply statutory requirements, the document is likely to affect the customer on-boarding/acceptance and customer monitoring processes of banks that are subject to DCB supervision. Does this mean that you may have to adjust your tax structuring in order to open or maintain a bank account in the Netherlands?

2. Background and objective of good practices

Financial institutions, including banks, have an important role in the prevention

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