Friday, 8 June 2012

Draft legislation with a proposed amendment to the Belgian thin capitalisation rule for certain financing activities

The Program Act of 29 March 2012 introduced a general thin capitalisation ('thin cap') rule into Belgian tax legislation. The new 5:1 debt/equity ratio is applicable to (i) loans whereby the beneficial owner is not subject to income taxes, or, with regard to interest income, is subject to a tax regime which is substantially more advantageous than the Belgian tax regime; and (ii) intra-group loans.
Source & more info: PKN