Last year, the OECD launched the Action Plan on Base Erosion and Profit Shifting (BEPS), identifying specific actions needed to equip governments with the instruments to address tax avoidance by multinationals. This aims at among others financial service companies (‘FSC’) with low substance levels. The Netherlands has a long history in accomodating such FSC’s and fully supports this OECD initiative. To be fit for the future, the Netherlands refreshed its substance rules. In case the new substance rules are met, genuine presence of the FSC can be presumed, resulting in full access to the extensive, and still rapidly growing, Dutch tax treaty network as well as other tax benefits based on domestic law. In practice, these new substance rules can still be easily met, but the rules should be carefully observed. Therefore, the Netherlands remain one of the most attractive countries to set up a holding and financial services company!