What is a Dutch CIT fiscal unity?
A Dutch CIT fiscal unity lets a parent company and one or more subsidiaries file a single corporate income tax return as one taxpayer (article 15 Dutch CIT Act 1969). Losses and profits are offset directly within the group. The parent files one combined return for the entire unity.
How does it work?
Within a fiscal unity, the results of all participating companies are combined into one taxable profit. If BV A earns €300,000 and BV B makes a €100,000 loss, the group's taxable profit is €200,000. Without a fiscal unity, BV A pays tax on the full €300,000 while BV B's loss sits as a carry-forward.
Transactions between entities within the unity are fiscally neutral: no CIT is triggered by intragroup transactions. The parent files one combined CIT return annually on behalf of the entire group.
The statutory requirements
Article 15 Dutch CIT Act 1969 sets the requirements for a CIT fiscal unity. You must meet all of the conditions below; a separate deadline applies for filing the request.
1. Ownership requirement (95%)
The parent holds at least 95% of the subsidiary's nominal capital on five dimensions: legal, economic, voting, profit and net assets (art. 15(1)).
2. Legal form requirement
The subsidiary is a bv or nv (or a comparable foreign legal form). The parent is a bv, nv, cooperative, mutual insurer, or a foundation or association admitted as a housing corporation (art. 15(4)(d) and (e)).
3. Residency requirement
Parent and subsidiary are effectively resident in the Netherlands; a foreign body with a Dutch permanent establishment can participate under conditions (art. 15(4)(c) and (8)).
4. Financial year requirement
Parent and subsidiary use the same financial year (art. 15(4)(a)).
5. Same profit rules
The same profit-determination provisions apply to parent and subsidiary (art. 15(4)(b)).
6. Not held as inventory
The parent does not hold the subsidiary shares as inventory (art. 15(4)(f)).
Start date and deadline
The unity starts at the time stated in the request, but not earlier than three months before filing (art. 15(9)); the inspector decides by ruling (art. 15(12)).
More detail in Requirements for a Dutch CIT fiscal unity 2026 and The 95% ownership requirement.
Benefits
- ✓Immediate loss offsetting between group entities in the same year.
- ✓Fiscal neutrality on intragroup transactions: no CIT on transfers within the unity.
- ✓One combined CIT return for the entire group, less administrative burden.
- ✓Reorganisations and asset transfers without immediate tax.
Full article: Benefits of a Dutch CIT fiscal unity.
Drawbacks and risks
- ⚠The 19% low rate (first € 200,000) applies once to the whole group, not per entity.
- ⚠Joint and several liability for CIT debts of the entire group (art. 39 Collection Act 1990).
- ⚠Recapture on asset transfers if a company leaves within six years (art. 15ai Dutch CIT Act).
- ⚠Losses during the unity stay with the parent when a subsidiary is deconsolidated.
Full article: Disadvantages and risks of a Dutch CIT fiscal unity.
How do you apply for a fiscal unity?
You complete forms Part A and Part B, and Part C only if a subsidiary already heads an existing fiscal unity, and mail them to your tax office. The request must be filed within three months of the consolidation date. Our tool fills in the forms from your KvK extracts, for € 39 excl. VAT per download.
Read the step-by-step explanation in How to request a Dutch CIT fiscal unity.
Want to end the unity later? Read Ending a Dutch CIT fiscal unity: how deconsolidation works.
Looking for information about the VAT fiscal unity? Read CIT fiscal unity vs VAT fiscal unity: what is the difference?.
Questions about the Dutch CIT fiscal unity
What is the difference between a CIT fiscal unity and a VAT fiscal unity?
They are two separate regimes. The CIT unity (art. 15 Dutch CIT Act 1969) lets groups file one CIT return and offset losses. The VAT unity (art. 7(4) Dutch VAT Act 1968) governs VAT. A group can participate in both simultaneously or in only one.
When does the fiscal unity take effect?
You choose the consolidation date. The request must reach the Belastingdienst within three months of that date. To consolidate as of 1 January 2026, the deadline is 1 April 2026.
What does it cost to request a fiscal unity?
The application to the Belastingdienst is free of charge. Our tool completes the forms automatically for € 39 excl. VAT.
Can a foreign company participate in a Dutch CIT fiscal unity?
A foreign entity may participate under certain conditions if it has a permanent establishment in the Netherlands and the subsidiary shares belong to that PE's assets. Consult a tax adviser for cross-border structures.
About this page: written by Lowkey Automation (Chamber of Commerce 42057580, Amsterdam). The tool was built by a Dutch tax adviser. Last checked against the sources below on 3 October 2026.
Sources
Does your group qualify?
Run the eligibility check in two minutes and download the completed Belastingdienst forms.
€ 39 excl. VAT for the completed forms