How it works for your tax advisory practice
Once it is clear the engagement falls under the Wwft, you open a case file, or import contacts through an integration. Trade names and SBI codes come in from the trade register by themselves. You record the director-shareholder, the holding and the operating company together in the structure, and a company report shows the group.
You send the NOAB onboarding as a procedure. Your client signs in with a code by email and goes through the steps in the client portal, from the NOAB terms and the VAT authorisation to their identity. If they stop halfway, they carry on later, and every signed document goes straight into their file. If the client has a holding company, the contract builder adds the holding clause to your engagement letter by itself, and your client signs it in the same portal.
You request the UBO declaration and the holding company’s annual accounts as separate actions. Each document lands with the right party, the holding or the director-shareholder. Templates for the UBO declaration, source of funds and the risk questionnaire are ready to use.
You screen the director-shareholder for PEP status, sanctions and adverse media, and the holding for country and sector as well. A hit on the holding counts for the whole file. To start screening as soon as the onboarding is done, you set up a workflow that notifies you straight away when there is a hit. For a foreign company you start in-depth research, with its sources attached.
In the risk questionnaire you record your own assessment. A reviewer approves or rejects the file, and the risk level sets the date of the reassessment. Default workflows re-screen the client on a fixed rhythm, and custom fields record the type of tax service. Templates for tax advisers are ready to use.
When the Wwft applies to your tax advisory practice
If you give tax advice on your own account, the Wwft, the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act, applies to you. Article 1a(4)(a) Wwft covers the tax adviser who practises independently, and anyone who independently and mainly carries out comparable tax work on a professional basis. What counts is the type of work, not a title or a membership.
Tax work around legal proceedings falls outside the Wwft. Article 1a(5) excludes work that determines the client’s legal position, representation and defence in court, and advice before, during and after proceedings. According to the BFT guidance, a first exploratory meeting normally falls under this, and once the engagement is clear, the firm checks again.
For tax advisers too, the BFT is the supervisor (Article 1d(1)(c)), working from the same specific guidance as for accountants. The NOB and the RB do not appear in Article 1d. According to the BFT annual report for 2025, about as many tax advisory firms filed reports as in 2024, but the number of reports fell again. In 2026 the BFT is also investigating international structures at tax advisers.
RiskResolve supports and records due diligence per client. Whether an engagement falls under the litigation exemption is the adviser’s own call, as are the firm’s risk assessment (Article 2b) and any report to FIU-the Netherlands.
Tax advisers’ questions on onboarding and the Wwft
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