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Dutch business glossary · Fiscal unity

What is a fiscal unity (fiscale eenheid)?

In a fiscal unity, a parent company and its subsidiaries file one corporate income tax return, as if they were one taxpayer. The parent must own at least 95% of the shares. Losses and profits within the group are set off against each other at once.

Updated 30 September 2026 · Figures for 2026

How it works

A holding with one or more operating companies can ask the tax authority to treat the group as one taxpayer for corporate income tax. The parent must own at least 95% of the shares of each subsidiary. All companies must have the same financial year and be established in the Netherlands.

Inside the unity, a loss in one company is set off against the profit of another in the same year. For corporate tax, the tax authority ignores transactions between the companies. The group can therefore transfer assets internally free of tax. The group files one return and receives one assessment.

A fiscal unity also has disadvantages. The first bracket of 19% applies once for the whole group. Separate companies would each have their own first bracket. Every company is jointly liable for the corporate tax of the group. If a subsidiary leaves the unity within six years after an internal transfer, tax on that transfer can become due.

A separate fiscal unity exists for VAT, with its own conditions: financial, organisational and economic ties. Within a VAT unity the companies invoice each other free of VAT and file one VAT return.

Example

A holding owns 100% of two operating companies. One makes €150,000 profit, the other €50,000 loss. In a fiscal unity, the group is taxed on €100,000 at 19%, which is €19,000. As separate taxpayers, the profitable company pays €28,500. The other company can set off its loss only against a future profit.

The figures

95%Minimum shareholding
19% up to €200,000, once for the groupFirst bracket in the unity
joint, for the corporate tax of the groupLiability

Questions people ask

Is a fiscal unity always better?

A fiscal unity is useful when one company has losses, when the group transfers assets internally or when the group wants one return. The group then has only one first bracket. A group with several profitable companies, each below €200,000, often keeps separate returns.

Can a foreign parent form a fiscal unity?

A foreign parent can form a unity between its Dutch subsidiaries (a sister unity). This is possible when the parent is established in the EU or in a treaty country with a non-discrimination clause. The foreign parent itself stays outside the unity.

Holdwise, Hoofddorp. We keep this definition in line with our Dutch and German glossaries, and the figures are those for the tax year 2026. Updated 30 September 2026.

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