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 condition is that the parent owns at least 95% of the shares of each subsidiary, that all companies have the same financial year and that they are established in the Netherlands.
Inside the unity, a loss in one company is set off against the profit of another in the same year. Transactions between the companies are invisible for corporate tax, so assets can be transferred within the group free of tax. The group files one return and receives one assessment.
The unity has a price. The first bracket of 19% applies once for the whole group, where separate companies would each have it. Every company is jointly liable for the corporate tax of the group. And when 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%: €19,000. As separate taxpayers the profitable company pays €28,500 and the loss waits for a future profit.
The figures
All 2026 figures: Netherlands tax rates 2026 · the 2027 figures: Netherlands tax rates 2027.
Questions people ask
Is a fiscal unity always better?
It helps when one company has losses, when assets are transferred within the group or when the group wants one return. It costs the extra first-bracket amounts. A group with several profitable companies below €200,000 each often stays with separate returns.
Can a foreign parent form a fiscal unity?
A foreign parent can form a unity between its Dutch subsidiaries (a sister unity) when it is established in the EU or in a treaty country with a non-discrimination clause; the foreign parent itself stays outside.
Holdwise, Hoofddorp. Definition and explanation maintained with the Dutch and German glossaries; figures from the central rates source, year 2026. Updated 16 September 2026.
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