Adding a subsidiary to an existing Dutch CIT fiscal unity

Yes, a new BV can join an existing Dutch CIT fiscal unity. The new subsidiary must independently meet all requirements of article 15 Dutch CIT Act 1969, including the 95% ownership test. You choose a separate consolidation date for that subsidiary and file the request within three months of it. You do not need to reapply for the existing unity.

Do you need to reapply for the whole fiscal unity?

No. An existing fiscal unity stays intact; you only add the new subsidiary. In practice this means you file an additional request for the new company that refers to the existing unity (the parent's RSIN). You do not need to complete Part A, the section on the parent company, again if the parent is already part of a running unity; you complete Part B for the new subsidiary. If you are unsure about the exact procedure (an additional request versus a new complete request), check directly with the Belastingdienst or with an adviser, since this can differ by situation.

What requirements must the new subsidiary meet?

The same five requirements that apply on first consolidation apply in full to the new subsidiary:

• The parent holds at least 95% of the new subsidiary on all five dimensions: legal ownership, economic ownership, voting rights, profit entitlement and net asset entitlement on liquidation. See the 95% ownership requirement for the detail.
• The new subsidiary is a BV or NV.
• The new subsidiary is actually established in the Netherlands.
• The financial year of the new subsidiary aligns with that of the existing unity.
• The new subsidiary is not an investment institution (FBI or VBI).

If the shares of the new subsidiary are certificated through a trust office (STAK), that blocks legal ownership and therefore blocks consolidation (HR BNB 1995/146).

What consolidation date do you choose, and what is the deadline?

As with a first consolidation, the three-month window of article 15(9) Dutch CIT Act 1969 applies: the request must reach the Belastingdienst within three months of the desired consolidation date. If you want the new subsidiary to join as of the date of the share transfer or incorporation, file the request in time. The full counting rule, including how to work with calendar months, is in Dutch CIT fiscal unity with retroactive effect.

Example: BV Parent buys all shares in BV New on 1 May 2026. If the parent wants BV New included in the existing unity as of 1 May 2026, the request must reach the Belastingdienst by 1 August 2026 at the latest.

What are the tax consequences of joining?

Pre-consolidation losses stay limited to own profit

Losses the new subsidiary incurred before the consolidation date are not lost, but after consolidation can only be set off against the profit attributable to that subsidiary itself (profit splitting, article 15ae Dutch CIT Act 1969). Read the full rule with a worked example in Pre-consolidation losses in a Dutch fiscal unity.

Intragroup transactions become neutral from the consolidation date

Transactions between the new subsidiary and the rest of the unity become fiscally neutral only from the consolidation date onward. Supplies from before that date fall outside the unity and count as third-party transactions.

Joint and several liability applies immediately

Once the new subsidiary is consolidated, it is jointly and severally liable for the CIT debts of the entire unity under article 39 Collection of State Taxes Act 1990, including debts that arose before it joined. That is a reason to check the existing unity's financial position beforehand in an acquisition.

What if the new subsidiary does not meet the requirements?

If the new subsidiary does not meet all five requirements, it stays outside the unity and files its own CIT return until the requirements are met. A common scenario: in a phased acquisition, the parent first holds less than 95%, for example through an earn-out structure. Consolidation can only happen once ownership crosses the 95% threshold.

Frequently asked questions

Can the new subsidiary consolidate retroactively to before the share purchase?

No. The consolidation date cannot precede the moment the parent meets the ownership requirement. Only from the moment the parent holds 95% can the three-month window start running for that subsidiary.

Does the existing fiscal unity get a new RSIN or name because of the expansion?

No. The existing unity and its RSIN stay unchanged. The new subsidiary is added to the unity's circle of members; the parent remains the filer.

Does the new subsidiary also need to form a VAT fiscal unity?

That is a separate assessment. The VAT fiscal unity does not automatically follow the CIT unity; it arises by operation of law once the interlinkage conditions are met. Read the difference in CIT fiscal unity vs VAT fiscal unity: what is the difference?.

Next step

First check whether the new subsidiary meets all requirements with the eligibility check. Then prepare the request with our tool. More on the regime as a whole: What is a Dutch CIT fiscal unity?.