Currently, the Dutch corporate income tax act allows a Dutch tax resident company to form a fiscal unity with its Dutch subsidiaries if it holds at least 95 percent of the legal and economic ownership of the subsidiaries. Forming a fiscal unity brings many advantages: tax losses can be offset against taxable profits and profits on intercompany transactions can be eliminated, essentially allowing the tax free transfer of assets and liabilities between all fiscal unity members. This could result in a lower effective tax rate.
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MNE Tax, 16 May 2016