Fiscal unity knowledge base

Articles on the Dutch CIT fiscal unity.

20 May 2026

How to request a Dutch CIT fiscal unity

Step by step: which forms you need, how the process works and what deadlines apply when requesting a CIT fiscal unity in the Netherlands.

20 May 2026

Dutch fiscal unity requirements (2026)

The statutory requirements for a Dutch CIT fiscal unity: ownership threshold, legal form, residency, financial year alignment and filing deadline.

20 May 2026

The 95% ownership requirement for a Dutch CIT fiscal unity

The ownership threshold for a Dutch fiscal unity covers more than share percentage. Explanation of the five dimensions and common misconceptions.

20 May 2026

Benefits of a Dutch CIT fiscal unity

What does a Dutch CIT fiscal unity deliver for your group? Loss offsetting, fiscal neutrality on intragroup transactions and one combined tax filing.

11 June 2026

Disadvantages and risks of a Dutch CIT fiscal unity

Joint and several liability, one low-rate bracket for the whole group, and the 15ai recapture rule: the downsides of a Dutch fiscal unity explained.

11 June 2026

Ending a Dutch CIT fiscal unity (deconsolidation)

How to end a Dutch CIT fiscal unity: voluntary request vs automatic termination, the 15ai recapture rule, loss allocation and liability after separation.

11 June 2026

CIT fiscal unity vs VAT fiscal unity: the difference

The Dutch fiscal unity for corporate income tax and for VAT are two separate regimes with different rules, different applications and different consequences.

18 June 2026

How to request a VAT fiscal unity in the Netherlands

A Dutch VAT fiscal unity is requested with a letter, not a form. Which documents to enclose, what the inspector tests and how the ruling works going forward.

18 June 2026

Interlinkage in the VAT fiscal unity: financial, organisational and economic

The three forms of interlinkage in art. 7(4) Dutch VAT Act 1968 are cumulative. The >50% test, joint management and the economic link (HR BNB 2014/7) explained.

18 June 2026

VAT fiscal unity by operation of law: ruling and liability

A Dutch VAT fiscal unity arises by operation of law on interlinkage. The ruling works going forward, not retroactively, with liability under art. 43 IW.

30 June 2026

Pre-consolidation losses in a Dutch fiscal unity

Pre-consolidation losses in a Dutch fiscal unity only offset the profit of that same company. How profit splitting works under article 15ae CIT Act.

13 July 2026

Dutch CIT fiscal unity with retroactive effect: the 3-month rule

Retroactive effect is possible, but the request must reach the Belastingdienst within 3 months of the consolidation date (art. 15(9) Dutch CIT Act).

13 July 2026

How long does a fiscal unity request take? Decision term

The CIT Act sets no decision term for a fiscal unity request. The Belastingdienst falls back on the Awb: generally 8 weeks after receipt, extendable.

19 July 2026

Adding a subsidiary to an existing Dutch CIT fiscal unity

Adding a BV to an existing Dutch CIT fiscal unity: the subsidiary must meet the 95% ownership test, with its own consolidation date and 3-month deadline.

19 July 2026

Corporate income tax filing within a Dutch fiscal unity: how does it work?

Within a Dutch CIT fiscal unity only the parent files one combined return. Intragroup transactions are eliminated and the low-rate bracket applies once.

19 July 2026

Invoicing between members of a Dutch VAT fiscal unity

Within a Dutch VAT fiscal unity, internal supplies are not taxable transactions: no VAT on intra-unity invoices. What does and does not fall outside the scope.

19 July 2026

Joint and several liability in the Dutch VAT fiscal unity (art. 43 IW)

Every member of a Dutch VAT fiscal unity is jointly liable for the full VAT debt under article 43 Invorderingswet 1990. How to limit your exposure.