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Belgium - ATAD Implementation in Belgium: An Analysis of the New Interest Limitation Rule

Country:
Belgium
Author:
W.E.C. Heyvaert; E. Moonen
Issue:
European Taxation, 2019 (Volume 59), No 7
Published:
13 June 2019
In implementing the ATAD Interest Limitation Rule, Belgium remained as investment-friendly as permissible, making use of the de minimis threshold of EUR 3 million, the possibility to share unused interest deduction capacity with Belgian group members and to carry forward any unused interest deduction capacity indefinitely. There is, however, some complexity in the rules, a high compliance burden, and some red tape associated with a transfer of unused interest capacity to affiliated Belgian companies.
 
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