How long does a fiscal unity request take? Decision term

Article 15 Dutch CIT Act 1969 sets a strict filing deadline for the request (three months after the consolidation date), but no specific term within which the Belastingdienst must decide. For that decision term, the general rule of the General Administrative Law Act (Awb) applies: generally eight weeks, with the possibility of an extension.

What term applies to the decision?

Because the Dutch CIT Act does not set a specific decision term for the fiscal unity request, the inspector falls back on article 4:13 of the General Administrative Law Act. That article provides that an administrative body decides within a reasonable term, and that this term has in any case expired if no decision has been given within eight weeks and no notice of a longer term has been sent.

In practice, this means the Belastingdienst aims to decide within eight weeks of receiving a complete request, but can extend that term if the assessment takes longer, for example with a complex group structure or missing documents.

What if the Belastingdienst misses the deadline?

Under article 4:14 Awb, the inspector must notify you if the decision will not arrive on time, and state a reasonable term within which you can expect it. If the Belastingdienst does not respond and the term lapses, you can formally put the authority in default under the Awb rules on penalties for late decisions.

Note that this concerns the term for issuing the ruling, not the consolidation date itself. The fiscal unity can still take retroactive effect up to three months before the request, even if the Belastingdienst responds later. Read more in Dutch CIT fiscal unity with retroactive effect.

How do you avoid delay?

• File a complete request: Part A, a Part B per subsidiary and, where applicable, Part C, with all KvK data and signatures.
• Check beforehand that the five requirements of article 15 Dutch CIT Act are met; see Requirements for a Dutch CIT fiscal unity 2026. Incomplete or unclear requests take the inspector longer to assess.
• File well before the statutory filing deadline, so there is margin left if the Belastingdienst asks for additional information (this suspends the decision term under article 4:15 Awb).

Decision term for the VAT fiscal unity

For the VAT fiscal unity this works differently: that unity arises by operation of law once the interlinkage is met, and the inspector's ruling is a confirmation that applies going forward. The Awb term still applies to issuing that ruling, but the fiscal unity does not need to wait for the ruling to exist. Read more in What is a Dutch VAT fiscal unity?.

Next step

Want to be sure your request is complete before you send it? Start with the eligibility check and read How to request a Dutch CIT fiscal unity. More on the regime as a whole: What is a Dutch CIT fiscal unity?.