Q: Why does it feel like the tax office knows everything about me, but I know nothing about them?
"Because that’s how the system works. You have to show all your numbers, but the Belastingdienst doesn’t have to share how they check or why they start an audit. That part stays hidden. The only thing you can do is keep your bookkeeping clean and be ready in case they come knocking."
The Dutch Tax Authority (Belastingdienst) recently published a decision following a request under the Wet open overheid (Woo – Open Government Act) concerning the handling of a VAT return and a subsequent tax audit. For many micro- and small-business owners, this might sound distant from daily reality. Yet this decision makes painfully clear how vulnerable you are once you become part of a tax control process.
This is not about whether you did “something wrong,” but about how information is gathered, shared, and withheld. And that directly affects trust, transparency, and the balance between entrepreneurs and government.
Key Takeaways from the Decision
- Tax secrecy always comes first: Under Article 67 of the General Tax Act (Awr), the Tax Authority cannot disclose personal tax data, not even via Woo.
- Limited openness of internal instructions: Some documents, like work procedures or guidelines, may be partially disclosed. But internal assessment criteria remain secret to protect control processes.
- Balancing transparency and supervision: The Tax Authority weighs openness against the effectiveness of inspections. If disclosure could lead taxpayers to “adapt their behavior strategically,” secrecy wins.
What This Means for You as an Entrepreneur
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Do not expect full access to internal files
If you are subject to a tax audit, you will never see the full picture. Internal instructions and evaluation points remain inside the Tax Authority. This means you are always operating with a knowledge disadvantage. -
Your tax file is closed to third parties
Even if someone requests access to your file through Woo, it will be denied because of tax secrecy. That protects your privacy, but it also means you cannot rely on outside scrutiny of the Tax Authority. -
Audits remain a black box
The reasons and internal discussions leading up to an audit are not fully disclosed. You must assume that decisions are made based on criteria you will never see.
The Practical Implications
For micro- and small-business owners in the Netherlands, this means:
- Preparation is crucial: Since you cannot know all the internal rules, your administration must always be structured to withstand scrutiny.
- Transparency is one-sided: You must show everything, while the Tax Authority does not have to reveal all its reasoning.
- Objection and appeal are your only tools: If you disagree with a decision (for example, a delay in a VAT refund), you must use the formal objection process. Woo will not help you here.
My Advice to Entrepreneurs
- Build a defensible administration: Not only tidy, but also logical and explainable.
- Watch for warning signs: Delays in VAT refunds or repeated additional questions can be an early signal of further investigation.
- Be ready for the long game: Transparency is not mutual. Your best protection is clarity, structure, and the discipline to keep your records watertight.
This decision reminds us: the Tax Authority controls the rules of the game, but entrepreneurs control how well prepared they are to play it.
SOURCE : Woo-besluit | 2025-524
Co-Founder of Xtroverso | Head of Ledger and Tax Compliance
Linda Pavan brings disciplined precision to Xtroverso, anchoring its financial, fiscal, and operational integrity. As a ZENTRIQ™ Certified Auditor, she translates complexity into clarity, ensuring every decision is traceable, compliant, and strategically sound. Her quiet rigor empowers businesses to act with confidence and accountability.
