The fiscal access right is arriving in stages, so company records still carry the first burden.
A founder does not ask for fiscal transparency at nine in the morning. She asks why an assessment is higher than expected, which message she missed, and whether the bookkeeper can show what was filed, when, and on what evidence. The language is simple because cash is simple. Can we prove our position before the deadline bites?
The economic route comes first
The legal route is now visible in Wettenbank, the government package of 16 September 2025, and the Belastingdienst Jaarplan 2026. Together they show a right that is real, but built in parts.
This is useful transparency with a practical warning attached. More access to the Belastingdienst dossier can help a taxpayer understand a decision. It does not remove the company’s own evidence burden.
The right is real, but staged
Article 66a AWR creates the legal route for access to data relating to the taxpayer or withholding agent. The 2025 legislative package says the point is plain: when an assessment or appealable decision is made, taxpayers and withholding agents should not sit at an information disadvantage compared with the inspector.
That sounds simple until it reaches the systems. The proposal works toward active access through the existing digital portals of the Belastingdienst and Douane. It also phases entry per national tax. Article 66b AWR gives a temporary route before a tax is fully designated under article 66a. Wettenbank also shows future changes, including one listed for 1 January 2032.
Legal form is not the whole story
The Belastingdienst Jaarplan 2026 makes the staged character clearer. It says the fiscal dossier will become available step by step from 2026, starting with income tax cases outside the business-profit category. The portal should show which documents are already available and which will follow.
A dossier is more than a folder
The hard part is practical as well as technical. The 2025 execution test labels the impact ingrijpend, meaning major in daily operations. It says current information systems are arranged around the inspector’s work, while many case-related documents sit across different applications and processes.
To turn that into a usable dossier, the Belastingdienst needs metadata that links documents to the right decision. It also needs a judgment on what can be shown and what must be shielded. The official material names risks such as wrong metadata, privacy breaches, protection of third parties and officials, effective control, and unhindered investigation.
The first step was costed at €24.6 million over 2025 and 2026, with later costs still to be worked out. Scale adds pressure. Belastingdienst figures for 2025 show 499,110 objections received and 377,310 handled. At year-end, 621,700 objections were still in stock, with three quarters concerning box 3.
Older rights still matter
The new active access right sits beside existing procedural routes. Article 7:4 Awb already provides for inspection of the objection file and further case-related documents before a hearing, with withholding possible for weighty reasons. In appeal, article 8:42 Awb requires the administrative body to send case-related documents to the administrative court. Article 8:29 Awb deals with restricted court-only knowledge for weighty reasons.
A Hoge Raad judgment of 4 May 2018, ECLI:NL:HR:2018:672, matters for digital tax files. The court confirmed that case-related material under article 8:42 Awb reaches beyond paper. It can include electronic data that can be made readable or otherwise perceptible, if relevant and consultable for the case. Software systems themselves generally fall outside that category.
For a small business, the distinction is practical. The question is which data, documents, notes, messages, and decisions belong to the tax position at that moment. A wider access right helps only when the company can compare the government file with its own records.
The company record still carries the decision
Return to the founder with the unexpected assessment. A better Belastingdienst portal may help her see more of the government side. She still needs the return, the submission confirmation, the invoices, the payroll calculation, the VAT codes, the bank movements, the adviser’s note, and the correspondence. She needs dates. She needs the reason a position was taken.
Follow one revenue stream
This is where governance becomes practical. The owner-manager, bookkeeper, or adviser should be able to reconstruct a material tax position without relying on memory. Mixed-use costs, payroll classifications, cross-border VAT choices, corrections, exemptions, and shareholder-related items all deserve a clear trail. The dispute usually arrives after the work should already have been done.
Privacy also belongs in the business reading. Fiscal documents can contain data about employees, officials, other taxpayers, and third parties. Redaction is part of the access right itself. Payroll-heavy employers should be especially careful about who can see tax material that contains staff data.
What changes tomorrow morning
A sensible review starts close to the desk. Can the business retrieve the last filed VAT, wage tax, income tax, or corporate tax return with submission confirmation? Are Belastingdienst portal messages saved? Are assessments, decisions, payment references, objections, hearing notes, and adviser emails kept together by tax type, year, assessment, and decision?
If the adviser holds part of the evidence, the owner should know which part sits only in the adviser’s system. If the business imports goods or works with customs permits, declarations, guarantees, or movement records, those papers deserve their own order. The Douane execution test also describes major implementation pressure, with better information management and later recalibration needed for the longer route.
Local taxes need separate attention. The 2025 explanatory memorandum placed provincial, municipal, and water board taxes outside the new active fiscal access right at that stage, while existing Awb access in objection and appeal remains relevant. A company should not assume that every levy will follow the same portal logic.
The calm conclusion is this: the fiscal access right improves the taxpayer’s position, but it will arrive through stages, filters, privacy checks, and old systems being made to serve a new purpose. That is progress, not magic. The Belastingdienst may show more of its reasoning. The company still has to know its own.
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