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ARTICLE · 26 JUNE 2026

Consolidation Exemption For Intermediate Holding Companies

Loyens & Loeff
Loyens & Loeff
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Loyens & Loeff

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The intermediate holding exemption in Dutch financial reporting law allows certain companies to avoid preparing consolidated financial statements, but its application requirements remain subject to interpretation and uncertainty in practice. This analysis examines the specific conditions that must be met to qualify for the exemption and explores the practical consequences and ambiguities that arise when companies attempt to apply Section 2:408 of the Dutch Civil Code.

NetherlandsAccounting and Audit
Loyens & Loeff
Loyens & Loeff

This Quoted explores the requirements for applying the intermediate holding exemption, highlights areas where interpretation may be unclear, and considers several additional consequences that may arise in practice.

Read the full publication in Dutch.

A commonly used exemption in Dutch financial reporting law is the so‑called intermediate holding exemption as laid down in Section 2:408 Dutch Civil Code. In essence, this exemption relieves an intermediate holding company from the obligation to prepare and publish consolidated financial statements, provided that the financial information of the intermediate holding and the entities within its scope of consolidation is included in the consolidated financial statements of a higher‑level entity.

The application of this exemption is subject to a number of requirements that must be satisfied. In practice, however, there is some uncertainty regarding the interpretation of these requirements.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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