What is a fiscal unity?

A fiscal unity is a tax grouping where a holding BV (besloten vennootschap, the Dutch private limited company) and its subsidiaries file a single consolidated corporate tax return. From a Vpb perspective, the group is treated as one entity. This means: losses in subsidiary A can immediately offset profits in subsidiary B, and intercompany transactions are eliminated.

When does fiscal unity make sense?

  • One group company is loss-making while another is profitable — immediate loss offset saves cash tax
  • Significant intercompany transactions that would otherwise create administrative complexity
  • New ventures under the holding that start with losses

Conditions for fiscal unity

  • Parent must own at least 95% of the shares in the subsidiary
  • Both entities must be Dutch resident (or have a Dutch PE)
  • Same financial year
  • Application submitted to Tax Authority (form: Vpb 95E)

Downsides of fiscal unity

  • Joint and several liability: all entities in the fiscal unity are jointly liable for the group's Vpb
  • The 19% bracket (€200,000) applies to the group as a whole rather than per entity — so two profitable BVs in a fiscal unity lose one €200,000 bracket
  • Dissolving the fiscal unity can trigger anti-avoidance provisions

Where this leads

Further along the same line: Tax Benefits of a Dutch BV in 2026, Real Estate via a BV and Dutch BV Tax Benefits 2026.