11 June 2026 · 4 min read
CIT fiscal unity vs VAT fiscal unity: what is 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.
The term "fiscal unity" (fiscale eenheid) refers to two completely separate tax regimes in the Netherlands: one for corporate income tax (CIT / VPB) and one for VAT (omzetbelasting / btw). Each has its own legal basis, requirements and consequences. Not sure which one you need? The comparison below will tell you immediately.
What is the difference?
The two regimes are independent of each other. You can have a CIT fiscal unity without a VAT fiscal unity, and vice versa. Here is a side-by-side comparison:
| Feature | CIT fiscal unity (VPB) | VAT fiscal unity (btw) |
|---|---|---|
| Legal basis | Art. 15 Dutch CIT Act 1969 | Art. 7(4) Dutch VAT Act 1968 |
| Tax | Corporate income tax | Value added tax (VAT) |
| Key requirement | Parent holds ≥95% in subsidiary (legally and economically) | Financial, organisational and economic interlinkage |
| Eligible entities | BV, NV (subsidiary); BV, NV, cooperative etc. (parent) | Any VAT entrepreneur, including sole traders, partnerships and foundations |
| Application | Written request (Part A + B forms) within 3 months of consolidation date | By operation of law (if interlinkage exists) or by inspector's ruling |
| Effect | One combined CIT return; loss offsetting; intragroup neutrality | One combined VAT return; internal supplies between members are outside the scope of VAT |
| Liability | Joint and several (art. 39 Collection Act 1990) | Joint and several (art. 43 Collection Act 1990) |
VAT fiscal unity: the interlinkage test (article 7(4) Dutch VAT Act)
For VAT, article 7(4) of the Dutch VAT Act 1968 provides that entrepreneurs that are financially, organisationally and economically interlinked are treated as a single VAT taxpayer by operation of law. The tax inspector may also issue a ruling to formalise the unity.
The interlinkage test is different from the 95% ownership threshold for CIT. Financial interlinkage means one entity controls the other (or a common owner controls both). Organisational interlinkage means the same persons manage both entities. Economic interlinkage means the activities are complementary or interdependent.
Example: BV Holding owns 100% of BV Operating. The same director manages both companies. BV Operating's activities directly serve the same customers as BV Holding. All three forms of interlinkage are present and the VAT fiscal unity arises automatically.
CIT fiscal unity: the 95% requirement (article 15 Dutch CIT Act)
The CIT unity requires the parent to hold at least 95% of the subsidiary's nominal paid-up capital, and to meet that threshold across voting rights, profit entitlement and net asset rights as well. This is a hard quantitative threshold. The unity does not arise automatically: you must file a written request with the Belastingdienst within three months of the desired consolidation date.
Read more about the CIT requirements in Requirements for a Dutch CIT fiscal unity (2026).
Which regime do you need?
Looking for information about combining VAT returns across group entities, or whether internal invoicing is subject to VAT? That is the VAT fiscal unity (art. 7(4) Dutch VAT Act 1968). Consult your VAT adviser or apply to the Belastingdienst for a ruling.
Want to file one combined CIT return, offset losses within the group, or treat intragroup transactions as CIT-neutral? That is the CIT fiscal unity (art. 15 Dutch CIT Act 1969). You can check here whether your group qualifies and complete the request forms.
Can both unities exist at the same time?
Yes. The CIT unity and the VAT unity are independent regimes. A group can participate in a CIT fiscal unity and at the same time form a separate VAT fiscal unity that covers different entities, or have no VAT unity at all. Note that the joint and several liability rules of both regimes apply simultaneously if you participate in both.
More information
Read more about the CIT regime in What is a Dutch CIT fiscal unity? and Benefits of a Dutch CIT fiscal unity. Ready to start a CIT request? Run the eligibility check.