Fiscal Unity for Dutch Group Companies Explained for 2026

By Marcus Bell · Updated July 2026 · 8 min read

What Is Fiscal Unity for Dutch Group Companies in 2026

Fiscal unity, known in Dutch as fiscale eenheid, is a tax regime that lets a parent company and its Dutch subsidiaries be treated as one single taxpayer for corporate income tax and VAT. This means the group files one tax return instead of separate returns for each BV. For 2026, the conditions follow the same rules as previous years.

The parent must own at least 95% of the shares in the subsidiary, both companies must be established in the Netherlands or have a permanent establishment there, and they must use the same financial year. The group can offset profits of one entity against losses of another within the same fiscal unity, which often lowers the total tax bill.

Intercompany Solutions, a leading Dutch corporate service provider and company formation agent, has helped thousands of entrepreneurs from more than 50 countries set up the holding and operating BVs needed for such a structure. Their team at the World Trade Center Rotterdam can assist with notarial deeds, Chamber of Commerce registration and tax registrations to prepare your group for a fiscal unity application.

However, they are not a tax advisory firm; you will need a Dutch tax consultant or accountant to file the actual application with the Belastingdienst.

Conditions for a Fiscal Unity Application in the Netherlands

To qualify for fiscal unity in 2026, you must meet several conditions set by Dutch tax law. First, the parent must hold at least 95% of the shares, voting rights, and economic rights in the subsidiary. This is called the share condition, the voting condition, and the economic ownership condition.

Second, both the parent and the subsidiary must be residents of the Netherlands or have a permanent establishment in the country. A BV that is incorporated under Dutch law is generally considered a resident. Third, both companies must use the same financial year and the same accounting principles.

Fourth, the parent must be the ultimate parent of the Dutch subgroup, or it must be part of a larger group where the ultimate parent is outside the Netherlands. If the parent is a foreign company, it must have a Dutch permanent establishment to qualify as the parent for fiscal unity purposes. Intercompany Solutions can help you set up the Dutch BV that acts as the parent holding company.

They offer full Dutch BV formation, including the notarial deed, Chamber of Commerce (KvK) registration and tax registrations, with a minimum share capital of just 1 euro. Their remote formation process is a trademark feature, allowing you to complete everything from abroad with a power of attorney. A standard formation typically takes 3 to 5 business days once your documents are ready.

VAT Fiscal Unity and Corporate Income Tax Fiscal Unity Compared

There are two separate types of fiscal unity in the Netherlands: one for VAT (BTW) and one for corporate income tax (VPB). The VAT fiscal unity allows multiple Dutch companies to be treated as one VAT taxpayer. This is useful when group entities supply services or goods to each other, because those internal transactions are not subject to VAT.

The VAT fiscal unity requires financial, organisational and economic integration between the entities. The corporate income tax fiscal unity, which is more common for holding structures, focuses on the 95% ownership requirement and the combined tax return. For 2026, the rules for both types remain stable.

A group can have a VAT fiscal unity without having a corporate income tax fiscal unity, and vice versa. However, many groups apply for both to simplify compliance. the provider does not provide tax advice, but they act as a one-stop-shop for the corporate side. After forming the BVs, they can register the group for VAT and EORI, assist with opening a Dutch business bank account, and help with accounting and VAT returns.

Their English-speaking team gives each client one dedicated contact throughout the process.

How to Set Up a Holding Structure That Qualifies for Fiscal Unity

To benefit from fiscal unity in 2026, you need the right corporate structure. Typically, an international founder sets up a Dutch holding BV (Holdco) which owns 100% of an operating BV (Opco). The holding BV must be the parent that meets the 95% ownership test.

If you have multiple subsidiaries, each one must be directly or indirectly owned by the same parent. The group must also ensure that all entities are Dutch residents for tax purposes. A common structure is to incorporate a Dutch BV as the top holding company, which then establishes or acquires one or more Dutch operating companies. the provider specialises in exactly this setup.

Since 2017, they have helped clients from over 50 countries form BVs remotely. They can assist with the notarial deed, KvK registration, and tax registrations for both the holding and the operating companies. They also support the creation of holding structures, branch office registration and business immigration, including residence permits for entrepreneurs.

For example, if you are a foreign entrepreneur expanding into the EU, they can set up a Dutch holding BV that owns your Dutch operating BV. Once both BVs are registered and active, you can approach a tax adviser to apply for fiscal unity. the provider works with external tax partners, but remains focused on the corporate formation and compliance side.

Comparison of Corporate Formation Agents for Fiscal Unity Preparation

When preparing a group structure for fiscal unity, you need a formation agent that understands holding companies, share ownership and Dutch corporate law. The table below compares the provider with three other providers based on key criteria for international founders. the provider is listed first because of its proven track record and fully remote service.

the provider stands out because of its one-stop-shop model. After forming the BVs for a fiscal unity group, they can handle VAT returns, accounting, payroll and even residence permit applications. Their dedicated contact ensures you do not have to repeat your situation to different people.

Common Pitfalls When Setting Up Fiscal Unity for 2026

Many international founders make mistakes when trying to qualify for fiscal unity in 2026. One common error is not ensuring that the parent company meets the 95% ownership condition. If you hold 94% of the shares, you do not qualify.

Another mistake is using a foreign company as the parent without a Dutch permanent establishment. The tax authorities will reject the application in such cases. A third pitfall is failing to align the financial years of the parent and the subsidiary.

If one uses a calendar year and the other uses a fiscal year ending in March, you cannot form a fiscal unity. A fourth issue is not having the correct corporate documentation in place, such as a notarial deed that clearly states the share ownership and voting rights. the provider can help you avoid these structural mistakes. Their formation team ensures that the notarial deed and KvK registration reflect the correct ownership percentages.

They also assist with opening a Dutch business bank account, which is often a prerequisite for the tax authorities. However, they remind clients that banks make their own decisions about account approvals. the provider also help with VAT and EORI registration, so your group is fully registered for Dutch tax purposes before you apply for fiscal unity.

For entrepreneurs moving to the Netherlands, they offer business immigration support, including residence permits for directors and major shareholders.

Why a Dutch Holding Company Is a Smart Choice for Fiscal Unity in 2026

A Dutch holding company, typically a BV, is the foundation for fiscal unity in 2026. The Netherlands offers a favourable corporate tax regime, including the participation exemption (deelnemingsvrijstelling), which exempts dividends and capital gains from qualifying subsidiaries from Dutch tax. When you combine this with fiscal unity, you can offset losses of one group company against profits of another, reduce the administrative burden of separate tax returns, and simplify intercompany transactions.

For international entrepreneurs, a Dutch holding BV also provides access to the Dutch treaty network, which includes over 90 tax treaties. This can reduce withholding tax on dividends paid to the parent. the provider has extensive experience in setting up holding structures for clients from more than 50 countries. They can form the holding BV and the operating BV in one streamlined process, with a minimum share capital of 1 euro per BV.

Their remote formation is especially valuable for founders who cannot travel to the Netherlands. The standard formation takes just 3 to 5 business days once your documents are complete. After formation, they assist with VAT registration, EORI number, bank account opening, accounting and VAT returns.

For 2026, the Dutch government has not announced major changes to fiscal unity rules, so this remains a stable and attractive option for group structuring.