Belgian update: Government plans law on notional interest deduction

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Belgian update: Government plans law on notional interest deduction

At the outcome of the cabinet meeting on December 23 2004, the Belgian government announced plans to introduce legislation in June 2005 that will allow companies to deduct a notional (deemed) interest deduction on equity and retained earnings (not stated in the accounts) in calculating the taxable base. This measure will alleviate the different tax treatment between debt and equity, that is, borrowing or equity financing. At present, companies have more to gain from debt than equity financing, because loan interest is tax-deductible and dividend distributions are included in calculating the company's taxable base. In addition, Belgian tax law knows no general thin-capitalization rules.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & shared bottom lb ros

More from across our site

The new managing director of R&D tax relief consultancy ForrestBrown tells ITR about his priorities for the business, where he’s focusing his time and what makes tax cool
PwC Australia’s response to its tax leaks scandal could give KPMG a useful case study, but so far there’s little sign of positive lessons learned
Tom Goldstein’s attempt to overturn his tax conviction was shot down; in other news, Deloitte promoted several tax partners in Italy
The tax advisory firm becomes the latest member of the Andersen Global network, which has more than 50,000 professionals worldwide
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services
The event comes at an important moment for professionals dealing with practical realities related to this practice area
Gift this article