To challenge a tax correction effectively, you need to know its basis. The assessment notice alone or a summary in a letter does not always provide sufficient insight. Therefore specifically request access to documents in your case and identify missing documents concretely. A tax lawyer can assess which documents are relevant, how a claim to confidentiality should be handled and which procedural step fits. Your own tax file differs from general policy information or another client’s tax file.
Sources (5)
On this page
Start with the purpose and stage of your request
Write down the decision challenged, tax years involved and corrections you want to check. Then state the case’s stage: questioning investigation, objection or appeal. The statutory route and significance of an access request depend on this. A general request for everything ever stored about you is less suited to a specific missing correction calculation.
For your lawyer, make a short list of what you have received and what references indicate is still missing. Examples include an audit report, an attachment containing bank transactions or a calculation referred to in a letter. Also keep the envelope or digital receipt details of the disputed decision. Access is a means to build your substantive defence; it does not replace timely filing of a remedy.
Connect access during objection with the hearing
The Tax Administration explains that before a hearing you are given an opportunity to inspect documents concerning your case. The invitation states where and when. In your objection, request a hearing and indicate that you want to study the file beforehand. Establish practical arrangements: on-site access, digital documents or copies.
Article 7:4 of the General Administrative Law Act governs access before the hearing. Discuss scheduling if important documents only become available shortly beforehand. Explain which preparation remains impossible as a result and request a specific solution. A request for extra time does not itself provide certainty that the hearing has been moved. Keep confirmation and note which documents you still want to discuss at the hearing.
Look beyond the assessment’s reasoning alone
A relevant file check concerns, for example, the origin of data, selection of transactions and method used to calculate a correction. Request documents enabling you to follow those steps. Beside an alleged turnover correction, list the source amounts you see and where reconciliation is missing. This practical comparison helps formulate a focused request.
Do not turn a suspicion into an established fact. A document’s absence from the folder you received does not yet prove that the inspector deliberately withholds it or that it exists. Refer to a date, passage or attachment number prompting your question. Also ask whether a mentioned attachment was part of an earlier package. This keeps the discussion verifiable and prevents the parties working at cross-purposes.
In court, documents relating to the case matter
On appeal, Article 8:42 of the General Administrative Law Act requires the administrative authority to submit documents relating to the case. The Supreme Court has explained that this is not limited to documents the inspector uses to defend their position. Relevant documents that did not guide their assessment may also fall within the obligation. Their significance to the dispute is what matters.
Therefore put a completeness dispute specifically before the court: identify the suspected document, its relevance and the basis for your suspicion. The obligation does not mean the inspector must gather every conceivable piece of new information. The distinction between existing file data and new investigation to be undertaken is important. Your lawyer can focus a request accordingly and respond if the inspector considers the information outside the case.
Define digital information and other taxpayers’ information
Relevant information need not be on paper. The Supreme Court also includes electronically recorded data among possible case documents. For a database, this may concern data relevant to your case and available for consultation, displayed in an appropriate form. A reference to a system therefore does not automatically mean no document can be provided.
This creates no general right to the complete system or other taxpayers’ files. Others’ data may be subject to confidentiality and privacy protection. Explain which comparison matters for your correction and have an adviser assess whether targeted information provision or another form of review is appropriate. Do not request, without defining scope, a competing business’s entire records or another client’s records from your adviser.
Confidentiality requires a specific assessment
Sometimes a document is partly supplied or confidentiality is claimed. Record the missing passage, reason given and what you consequently cannot check. Third-party privacy may matter, but a general reference to confidentiality does not answer every procedural question. Have an adviser assess whether the limitation is sufficiently explained and which interests must be balanced.
In court, Article 8:29 of the General Administrative Law Act contains a separate scheme for restricted access or confidentiality. Discuss with your lawyer how to respond to such a request and what any consent means. The outcome of a document dispute is not predetermined. Nor does an incomplete file automatically lead to quashing an assessment; the missing material’s significance and procedural rules require separate assessment.
Use the Open Government Act and GDPR for their own purposes
An Open Government Act request concerns public disclosure of government information. The Tax Administration explains that personal tax-file information is confidential and is not made public through that route. The GDPR route provides access to your own personal data. That, too, is not automatically the same question as access to every document needed to challenge a particular tax assessment.
Therefore discuss the purpose before filing: do you want to check the basis of your assessment, inspect personal data or request general policy? Keep the requests recognisably separate and meanwhile monitor objection and appeal deadlines. Bring a document list, earlier access requests and responses to your lawyer. A focused engagement may cover checking file completeness, formulating an additional request and preparing the defence based on it.
Frequently asked questions
Must I wait to object until I have the file?
No, do not assume that. Monitor the applicable deadline and, if necessary, request time to supplement grounds later. An access request does not automatically suspend that deadline.
Do I also get someone else’s tax file?
There is no general right to another person’s complete client file. Any relevance of particular information must be assessed specifically, with attention to confidentiality and privacy.
Can I request my tax file through the Open Government Act?
That Act is intended for public disclosure. The Tax Administration refers to GDPR access for your own personal data; procedural routes apply to documents in objection and appeal proceedings. Choose the route matching your purpose.
Sources
These sources relate to this page. For a specific case, check current rules and your own documents.
- Belastingdienst — hoorprocedure bij bezwaar Accessed: 2026-10-23
- Rijksoverheid — na een bezwaar Accessed: 2026-10-23
- Hoge Raad 4 mei 2018 — ECLI:NL:HR:2018:672 Accessed: 2026-10-23
- Belastingdienst — Woo-verzoek Accessed: 2026-10-23
- Gerechtshof Den Haag — ECLI:NL:GHDHA:2025:2813 Accessed: 2026-10-23
Legal review
Not legally reviewed yetThis version has not been reviewed by a lawyer or legal professional. Checking sources or editing text is not legal approval.
Editorial team Tax law in the Netherlands
We connect explanations to sources and record targeted changes. Legal review is attributed only to the actual reviewed version, with a real reviewer, date and scope. Human legal review of these articles remains open.
Ricardo van der Spoel
Editorial responsibility · Editorial organisation and technology