Belgium: Changes to the new thin capitalisation rules
01 July 2012
The Belgian federal government has approved a new draft programme law
at its meeting of May 11 2012 which has been submitted to parliament on
May 15 2012. The draft law modifies the recently approved thin
capitalisation rule to ease its negative consequences for treasury
centres in Belgium.
|Dirk Van Stappen|
According to the thin capitalisation rules as foreseen in article
198, 11° of the Belgium Income Tax Code as recently changed by the
Programme Law of March 29 2012 (published in the Belgian Official
Gazette on April 6 2012), the deduction of interest paid on loans will
be disallowed in case, and to the extent of the excess, the total amount
of these loans is higher than five times the sum of the taxed reserves
at the beginning of the taxable period and the paid-up capital at the
end of this period.
The deduction limitation...
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