Benefits of a Dutch CIT fiscal unity

A Dutch CIT fiscal unity brings direct tax benefits for many groups. Here are the four advantages that matter most in practice.

1. Loss offsetting within the group

The main benefit: losses in one group entity offset profits in another automatically, in the same year. You do not have to wait for carry-forward loss relief in a future year.

Example: BV Holding earns €0. BV Operating Company A earns €500,000. BV Operating Company B has a loss of €200,000. Within the fiscal unity, taxable profit is €500,000 minus €200,000 = €300,000. Without a fiscal unity, A pays tax on the full €500,000 while B's loss sits as a carry-forward.

2. Fiscal neutrality on intragroup transactions

Transactions between entities within the fiscal unity are fiscally neutral. Asset transfers, service fees, interest on intragroup loans: as long as the entities are in the unity, none of these trigger immediate tax.

This makes reorganisations and shifts of activities within the group significantly simpler and cheaper.

3. One combined tax return

The parent company files one combined CIT return for the entire fiscal unity. That reduces administrative work, especially for groups with multiple operating entities.

4. Reorganisation facilities

Transfers of assets and liabilities within the fiscal unity do not, in principle, trigger immediate tax. Restructuring the group becomes considerably simpler: you can merge or split activities without immediate tax consequences.

When is the benefit greatest?

A fiscal unity is most valuable for groups where:

• one entity structurally runs at a loss while another makes a profit
• assets or activities are regularly transferred within the group
• multiple operating entities share overhead costs

Ready to get started?

Check whether your group qualifies via our eligibility check, then complete the request form in five minutes.