Caribbean Netherlands Introduces ABB Fiscal Unity from 2027

Summary 

• The 2027 tax proposals for Bonaire, Sint Eustatius and Saba introduce an ABB fiscal-unity mechanism, subject to parliamentary approval. Qualifying BES-established parent and subsidiary companies may jointly request treatment as one entrepreneur or producer for general expenditure tax, allowing qualifying intra-group supplies and services to be disregarded for ABB purposes. 

• The parent must hold full legal and economic ownership of the subsidiary’s shares, and a fiscal unity may include multiple subsidiaries. All included entities will be jointly and severally liable for ABB debts. The benefit of reducing tax accumulation therefore comes with wider payment, governance and due-diligence exposure across the. 

• Groups should model recurring intra-group ABB, verify establishment and ownership, map supply chains and assess whether an election produces a net benefit. Applications, effective dates, entity changes, exits and reconciliations need governance. Joint liability also supports stronger controls over filings, payments, intercompany agreements and acquisitions involving entities included in the. 

Extended article 

The 2027 tax proposals for the Caribbean Netherlands introduce a fiscal-unity mechanism for the general expenditure tax, known as ABB. Subject to parliamentary approval, qualifying parent and subsidiary companies established in Bonaire, Sint Eustatius or Saba may jointly request treatment as a single entrepreneur or producer for ABB purposes. The principal benefit is that qualifying supplies and services within the approved fiscal unity can be disregarded for ABB. This may reduce tax accumulation where goods or services pass through several group entities before reaching an external customer. The mechanism is elective rather than automatic, so groups need to compare the 

benefit with the compliance and liability consequences. HBN Law & Tax reports that the parent must own all legal and economic rights in the subsidiary’s shares. Multiple subsidiaries may be included. The rules also impose joint and several liability for the fiscal unity’s ABB debts, meaning each participating entity may be exposed to liabilities generated elsewhere in the group. Before applying, businesses should verify BES establishment, legal ownership, economic ownership and the proposed perimeter. They should map intercompany flows, current ABB leakage, external supplies and input costs. A numerical model should distinguish tax genuinely eliminated from timing differences or amounts 

already recoverable through pricing. Governance is equally important. The group should assign responsibility for returns, payments, reconciliations and correspondence with the tax administration. Intercompany agreements should address data provision, funding and indemnities for shared liabilities. Acquisitions, disposals, reorganisations and changes in ownership may affect eligibility and should trigger a review. The fiscal unity should not be confused with a corporate-income-tax consolidation or an EU VAT group. Its effects follow the specific ABB legislation for the BES islands. Final commencement, application procedures and detailed conditions depend on the enacted legislation and administrative guidance. Groups should therefore avoid changing invoice treatment until. 

Official sources: Dutch Senate legislative dossier 

External articles: HBN Law & Tax: BES tax changes for 2027 | HBN Law & Tax: fiscal-unity consultation 

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