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Belgium - Courts Hold That Notional Interest Deduction Does Not Require Substance

Country:
Belgium
Author:
F. Mortier
Issue:
International Transfer Pricing Journal, 2016 (Volume 23), No 4
Published:
18 July 2016
The Courts of Appeal of Antwerp and Liège are of the opinion that interposing a Belgian finance company is, as such, not abnormal even if the company holds one single loan. The receiving and granting of a loan, and the management thereof, is clearly an economic activity, and – given the magnitude of the loan – not of an abnormal nature. The notional interest deduction is not conditional upon a certain level of economic substance.
 
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