What each country checks
In the Netherlands, the Tax Administration looks at real practice. This means a real office, local administration and board decisions that are clearly taken in the Netherlands. The standard is strict but predictable. See the standard in full and the 2026 checklist. In Luxembourg, the focus is on the composition of the board and on local spending. In Ireland, the test is where central management and control are. The zero-withholding states check more strictly for letterbox companies, because their tax rates are low. Across the EU, modern treaties contain a principal purpose test. Under this test, the tax authorities check the purpose behind every claim.
One file for all countries
You need a real office and people who handle the administration. Decisions are minuted where they are taken, and agreements are at market prices (at arm's length). The board meets regularly, ideally every quarter. You build this file once. You then use it for the Dutch practice, the treaty tests and the bank checks. See substance and treaty access.
If you already have a Dutch company and want help with the paperwork, see corporate services in the Netherlands. One English-speaking team can do the bookkeeping, the VAT, the payroll, the annual accounts and the KVK filings for you.
The notary, the Tax Administration and the bank all ask for the company address first. You choose that address and sign the contract yourself. See what the law asks of a business address in the Netherlands.
Where structures fail
Structures rarely fail because of the rules. They fail because the work is irregular. Examples are a holding whose decisions are clearly taken in another country, or minutes written only after someone asked about them. The solution costs little money. It mainly takes discipline.