Reselling the licenses to the secondary company, no. not via VCPP, however If the holding company is the one that has the VSSP /VCPP agreement with VMware then yes. ALL reporting must be done via the holding company. and not the secondary company.
But what about "White Label Model for Rental License" from VMware Service Provider Program Guide Q4/2018 ?
The “White Label” model is a model whereby a Service Provider (a “Master Service Provider”) resells its Hosted IT Service to another Service Provider (a “Secondary Service Provider”) ....
I understand what you are saying but that is an agreement between you and your subsidiary company.
Part of that agreement is that they will report their usage to the parent company, it is the parent companies responsibility to report the combined numbers to VMware - VMware has no part in the sub-letting of your licenses. but you are expected to report all details.