What are the requirements for a Dutch VAT fiscal unity?

Three forms of intertwinement, all required at the same time: financial (more than 50% of the shares, including control, held by the same parties), organisational (a shared, unified management, or one entity factually subordinate to another) and economic (predominantly the same economic purpose, or over 50% complementary activities, with non-negligible mutual relations). All three must be present. Basis: article 7(4) of the Dutch VAT Act 1968 (Wet OB).

What counts as financial intertwinement for a VAT fiscal unity?

Financial intertwinement means more than 50% of the shares, including control, are held by the same parties. This is a lower threshold than the 95% requirement for the corporate income tax fiscal unity. For a foundation, comparable control applies instead of shares.

Does a VAT fiscal unity decision work retroactively?

No. A VAT fiscal unity arises by operation of law once the intertwinement requirements are met; a decision from the Dutch Tax Authority confirms this, but it applies only going forward. This is a key difference from the CIT fiscal unity formation request, which can have up to three months of retroactive effect.

Fiscal unity (VAT)

VAT fiscal unity request: intertwinement and the letter.

The data of the intertwined entities goes in, a request letter to the Dutch Tax Authority with the intertwinement reasoning (financial, organisational, economic) comes out. There is no official form for the VAT fiscal unity, only a decision you request with a letter.

Create account The requirements for the request € 39 / document, excl. VAT

VAT Fiscal Unity Request Letter

Entity A HoldCo Netherlands B.V.

Entity B OpCo Services B.V.

Financially intertwined Present

Organisationally intertwined Present

Economically intertwined Present

Format Letter, no form

Request letter

The requirements for the VAT fiscal unity

Art. 7(4) Dutch VAT Act

A Dutch VAT fiscal unity treats intertwined entities as a single VAT taxable person. Transactions between the entities fall outside the scope of VAT, and the unity files one combined VAT return. The requirements are in article 7(4) of the Dutch VAT Act 1968 (Wet OB). Note: this is the fiscal unity for VAT, not the corporate income tax fiscal unity. That is a separate regime with a higher shareholding threshold and its own form; see CIT fiscal unity.

What are the three forms of intertwinement?

Financial, organisational and economic, and all three must be present at the same time. If one is missing, there is no VAT fiscal unity, no matter how strong the other two are.

Financial: more than 50% of the shares, including control, held by the same parties. For a foundation, comparable control applies instead of shares. This is a lower threshold than the 95% requirement for the CIT fiscal unity.
Organisational: a shared, unified management across the entities, or one entity factually subordinate to another.
Economic: the entities predominantly serve the same economic purpose, or over 50% of activities are complementary, with non-negligible mutual relations (Dutch Supreme Court, BNB 2014/7).

A detailed explanation of each requirement: requirements for a Dutch VAT fiscal unity.

Who can be part of a VAT fiscal unity?

Every member must be a VAT taxable person (article 7(1) Dutch VAT Act) and be established in the Netherlands or have a Dutch fixed establishment. Unlike the CIT fiscal unity, not every member needs to be a BV or NV: at least one participant must be a legal entity, but sole traders and partnerships may also join. A pure, passive holding company with no trading activity of its own generally does not qualify.

Does the decision work retroactively?

No. A VAT fiscal unity arises by operation of law as soon as the three intertwinement requirements are met, even without a decision. A decision from the tax inspector provides certainty, which in practice is often needed for a bank, a client, or an accountant, but that decision applies only going forward. This is a material difference from the CIT fiscal unity formation request, which can have up to three months of retroactive effect.

Is there an official form?

No. Where the CIT fiscal unity has a standard form (Part A and Part B), there is no official AcroForm from the Dutch Tax Authority for the VAT fiscal unity. The request for a decision is a letter to the tax inspector, with the details of the entities involved and a written case for the financial, organisational and economic intertwinement.

Who is liable for the VAT debt?

Every entity in the fiscal unity is jointly and severally liable for the VAT debt of the entire unity, under article 43 of the Dutch Collection of State Taxes Act 1990 (Invorderingswet). This applies even to an entity that generated none of the underlying taxable turnover itself. Factor this in before entering a VAT fiscal unity.

Sources: article 7 Dutch VAT Act 1968 (wetten.overheid.nl) and the Belastingdienst on the VAT fiscal unity. Last updated: July 2026.

How it works

Three steps

Enter the intertwined entities once

The data for each entity joining the fiscal unity, plus the facts behind the financial, organisational and economic intertwinement. 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 whether the intertwinement requirements are met.

Request letter with intertwinement reasoning in one pass

The tool drafts the request letter from the same input, with the financial, organisational and economic intertwinement written out as reasoning. The drafting is deterministic, so the same input gives the same letter every time.

You check, sign and send

You get back the request letter, ready to sign. The test against the intertwinement requirements of article 7(4) Dutch VAT Act, the review and sending stay with your firm.

What the tool does and does not do

Does	Draft the request letter from one input, with the intertwinement reasoning written out, ready to sign.
Does	Read uploaded extracts or articles of association so you do not retype the company data.
Does not	Test whether the financial, organisational and economic intertwinement requirements are met, or send the letter for you. That judgement stays with you.

Looking for the CIT variant? The corporate income tax fiscal unity uses a different formation request, with an official form (Part A and Part B) and a 95% threshold. Read Dutch fiscal unity request (CIT).

Does your client want to file the request themselves? The self-service option for drafting the VAT fiscal unity request letter is at fiscale-eenheidsverzoek.nl/en/btw.

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.

Create account How we handle data

Frequently asked questions

What do I get back?

The VAT fiscal unity request letter to the Dutch Tax Authority, with the details of the entities involved and the intertwinement reasoning (financial, organisational, economic) written out, ready to sign and send.

Does the tool test whether the VAT fiscal unity is possible?

No. The tool drafts the letter from the entity data you provide. The test against the intertwinement requirements of article 7(4) Dutch VAT Act and sending the letter stay with your firm.

Is the client data stored?

No. Uploads and data are processed to produce your request letter and then discarded. We keep a billing line, never the contents. Everything runs on EU infrastructure. Read how we handle data.

What does a request letter cost?

€ 39 per finished document, excl. VAT. No subscription, no seats, no setup fee. You only pay when a document is produced.