Environmental tax refund selection module

Dutch Tax and Customs Administration

When processing requests for environmental tax refunds, the Tax and Customs Administration uses the Environmental Tax Refund Selection Module. This is to assist in processing these requests.

Last change on 13th of November 2025, at 13:38 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: Field not filled in.
• Status: In use

General information

Theme

Public finance

Begin date

Field not filled in.

Contact information

[e-mail]

Link to publication website

https://over-ons.belastingdienst.nl/onderwerpen/omgaan-met-gegevens/algoritmeregister/

Link to source registration

https://over-ons.belastingdienst.nl/onderwerpen/omgaan-met-gegevens/algoritmeregister/selectiemodule-teruggaaf-milieubelasting/

Responsible use

Goal and impact

Environmental tax refunds are schemes that allow citizens and businesses to get back (part of) environmental taxes paid under certain conditions. These include, for example, energy tax, coal tax or tax on tap water. The refund is intended to correct situations where taxes have been paid on energy or raw materials that were not actually consumed, or used for exempt purposes, such as production processes or renewable energy generation. Applications for refunds must be substantiated with data on consumption and purpose of use, and submitted to the Tax Administration according to set deadlines and conditions.

When processing applications for the refund of environmental taxes, the Tax and Customs Administration uses the Environmental Tax Refund Selection Module. This supports the processing of these requests.

All requests for the refund of environmental taxes go through the selection module. The selection module contains several selection rules that look at the content of the refund requests and can be used to detect an uncertainty or potential compliance risk in the requests. Different selection rules can be applied for each refund scheme. Based on the selection rules with associated limit, the algorithm assesses whether the request can be granted directly. If an uncertainty and/or possible compliance risk is detected, it is then checked and assessed manually, by a Tax Administration employee. After this, the request is settled. If no uncertainty or possible compliance risk is detected, the request is automatically granted.

Considerations

Correct and timely processing of refund requests is important for citizens and businesses. We want to do this carefully. The algorithm can support a Tax Administration employee in this. As a result, the assessment is more careful, efficient and uniform.

The algorithm contributes to the systematic and accurate checking of requests. By deploying an algorithm, these requests can be processed faster. As a result, citizens and businesses get clarity faster. The algorithm determines the assessment based on the relevant data. The alternative is for an employee to manually collect and assess the data for all requests. This would make the process more error-prone and takes more time.

Human intervention

Human intervention in the context of the Tax Administration implies that a competent and knowledgeable employee plays a substantial role in decision-making.In the operation of the algorithm, human intervention is involved, but decisions are also made by the algorithm. Based on the selection rules, the algorithm assesses whether the environmental tax refund request can be granted directly (in accordance with the request). If this is not the case, for example in case of detected uncertainties or a potential compliance risk, the request is manually assessed by a Tax Administration employee.

Risk management

The General Administrative Law Act (Awb) requires the government's actions to be transparent and lawful. The Tax Administration observes the general principles of good governance when applying and developing algorithms.

The algorithm uses data collected under various tax laws. As required by the AVG, no more data than necessary is used.

The algorithm was developed by staff at the Tax Administration and is also maintained internally.

Legal basis

1. General State Tax Act:
2. General Administrative Law Act:
3. General Data Protection Regulation:
4. General Data Protection Regulation Implementation Act:
5. Citizen Service Number (General Provisions) Act:
6. Archives Act 1995:
7. Environmental Taxes Act:

Links to legal bases

• General State Tax Act:: https://wetten.overheid.nl/BWBR0002320/
• General Administrative Law Act:: https://wetten.overheid.nl/BWBR0005537/
• General Data Protection Regulation:: https://eur-lex.europa.eu/legal-content/NL/TXT/HTML/?uri=CELEX:32016R0679
• General Data Protection Regulation Implementation Act:: https://wetten.overheid.nl/BWBR0040940/
• General provisions Citizen Service Number Act:: https://wetten.overheid.nl/BWBR0022428/
• Archives Act 1995:: https://wetten.overheid.nl/BWBR0007376/
• Environmental Taxes Act:: https://wetten.overheid.nl/BWBR0007168/

Elaboration on impact assessments

• Privacy and AVG

The use of data is tested against the General Data Protection Regulation (AVG). Reviewing personal data will highlight any privacy risks and allow appropriate measures to be taken.

Among other things, the AVG prescribes that no more data should be used than necessary. This is called data minimisation. The Tax and Customs Administration regularly examines whether the data used are still necessary and may therefore be used.

• Use of special personal data

Special personal data and/or data relating to criminal convictions and offences are not used.

• Equality and non-discrimination

The algorithm is assessed in line with applicable non-discrimination principles for direct and indirect discrimination. Processing as little personal data as possible reduces the risk of direct discrimination. Employees involved in developing and managing the algorithms receive training on data protection and bias.

Operations

Data

• Personal data taxpayer
• ANBI status
• VPB (corporate income tax) liability

Links to data sources

• Personal data taxpayer: Basisregistratie Personen (BRP)
• ANBI status: ANBI-Register Belastingdienst
• VPB (corporate income tax) liability: Belastingdienst

Technical design

The algorithm consists of selection rules drawn up by content experts based on laws, regulations and expertise

Based on the selection rules, the algorithm assesses whether the refund can be accepted immediately. If not, the refund is manually assessed by an employee.

The algorithm is not self-learning. This means that the algorithm does not develop itself during its use.

External provider

The algorithm was developed by staff at the Inland Revenue and is also maintained internally.