ATAD interest limitation rules implemented in Belgium

Anti Tax Avoidance Directive - Status after RD 20-12-2019

A Royal Decree on the interest limitation rules provided by the Anti-Tax Avoidance Directive (‘ATAD’) was published just before the end of last year. This was important, because the previously-enacted legal framework (the Law of December 25, 2017 and the Law of July 30, 2018) had left some important modalities open to be adopted by Royal Decree. Thanks to the Royal Decree’s publication, the interest limitation rules can now apply as of tax year 2020, as required by the ATAD.

Under the ATAD interest limitation rules, exceeding borrowing cost is disallowed to the extent that it exceeds either € 3 million, or 30% of the tax-adjusted EBITDA.

Read more here.

Download the summary here.

Interest Limitation Rules

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