Technically, registration as a withholding agent (by a foreign employer) should be done two (2) months after the month the Dutch withholding obligation for the foreign employer commenced.
In practice, however, it often occurs that the registration is done at a later date. This does not need to pose a problem as long as it is done in the same year the Dutch withholding obligation commenced. However, interest and penalties may become due for the late withholding, filing, and payment of the payroll taxes to the Dutch tax office.
For late registration as a withholding agent, a penalty can become due up to a maximum of 10% of the amount that has effectively been paid late. In addition, interest may be charged.