Fiscal unity (CIT)
A corporate income tax fiscal unity (fiscale eenheid VPB) is formed by filing a request with the Dutch Tax Authority: Part A for the parent and one Part B per subsidiary. Below are the rules your firm checks (requirements, filing window, retroactive effect, decision timeline), plus the tool that fills Part A and Part B from one input, consistent and ready to sign.
A Dutch corporate income tax fiscal unity lets a parent and its subsidiaries file a single CIT return. Losses and profits within the group are set off directly, and intercompany transactions are tax-neutral. The requirements are in article 15 of the Dutch Corporate Income Tax Act 1969 (Wet Vpb). Note: this is the fiscal unity for corporate income tax, not the VAT fiscal unity. Those are separate regimes with separate rules.
The request must reach the Belastingdienst within three months after the desired effective date of the fiscal unity. For a unity starting on 1 January 2026, the request must be in before 1 April 2026. The basis is article 15 Dutch CIT Act and the Fiscal Unity Decree 2003 (Besluit fiscale eenheid 2003).
Yes, but only up to three months back from the date of filing. The effective date of the fiscal unity cannot be earlier than three months before the request is submitted. This window is commonly used when a restructuring closes partway through a quarter: you file the request once the legal structure is in place and work back to the desired effective date. Going back further than three months is not allowed.
Example: you file on 15 March 2026, so the earliest possible effective date is 15 December 2025. Note that the 95% ownership requirement must already have been met on that earlier date.
The core requirement is that the parent holds at least 95% of the shares and voting rights in the subsidiary, directly or via another entity already in the fiscal unity (article 15(2) Dutch CIT Act). Shares held through a STAK (trust office foundation) do not count towards this threshold. In addition:
All requirements must be met on the desired effective date. The assessment stays with your firm; the tool fills in the request from the data you supply.
The Belastingdienst aims to issue a formal decision (beschikking) within 8 weeks of receiving a complete request, under article 4:13 of the General Administrative Law Act (Awb). The decision is open to objection within six weeks. In complex restructuring cases or when the inspector requests additional information, the timeline may run longer. Factor this into your planning.
Within the fiscal unity, losses of one entity are set off directly against profits of another, the group files a single CIT return, and intercompany transactions are tax-neutral. The main drawbacks: the lower CIT bracket applies only once across the entire unity, and all entities are jointly and severally liable for the group's CIT debt.
A fiscal unity ends on request or when the conditions are no longer met, for example because the parent drops below the 95% threshold. From the termination date, each entity files its own CIT return again. Watch the six-year rule: if assets were transferred within the unity, winding it up within six years can trigger a clawback. Termination is handled separately with the Belastingdienst; this tool covers the formation request only.
Sources: article 15 Dutch CIT Act 1969 (wetten.overheid.nl) and the Belastingdienst on the fiscal unity for CIT. Last updated: June 2026.
The data for the parent company and each subsidiary joining the unity. Have extracts or articles of association as uploads? The tool reads them so you do not retype the company details. A model only reads the upload, it never decides the numbers.
The tool fills Part A and Part B from the same input, so the data matches across both parts. The form-filling is deterministic, so the same input gives the same request every time.
You get back the filled request, ready to sign. The test against the conditions of article 15 Dutch CIT Act, the review and the filing stay with your firm.
What the tool does and does not do
Does your client want to file the request themselves? The self-service option for companies filing their own formation request is at fiscale-eenheidsverzoek.nl.
Pricing
€ 39 / document, excl. VAT
You are billed per finished document, collected monthly through Stripe. No seats, no minimum, no setup fee. Draft, review and discard as much as you like. You only pay when a document is produced.
The corporate income tax fiscal unity formation request, Part A and Part B filled in, consistent across both parts and ready to sign and file.
No. The tool fills in the request from the parent and subsidiary data you provide. The test against the conditions of article 15 Dutch CIT Act and the filing stay with your firm.
No. Uploads and data are processed to produce your request and then discarded. We keep a billing line, never the contents. Everything runs on EU infrastructure. Read how we handle data.
€ 39 per finished document, excl. VAT. No subscription, no seats, no setup fee. You only pay when a document is produced.
Further reading on the fiscal unity request: