Interest Limitation Rules in the Post-BEPS EraTell, Michael
The interest limitation rules, include an equity-escape carve-out where the taxpayer is a member of a consolidated group, and the taxpayer’s ratio of equity over total assets is equal (defined as up to 2% lower) or higher than the equivalent ratio of the group. Ho...
The final rules scale back the definition of interest, which is subject to an anti-abuse rule that curtails the use of tax-motivated planning to avoid the limitation. If your deduction for business interest has been limited, the change that reduces the amount of your expenses subject to the ...
Luxembourg securitisation vehicles covered by EU Securitisation Regulation will no longer be exempt from Luxembourg interest limitation rules. 17 March 2022 Publication Print Publication Share Publication The Luxembourg law which implemented the first European Union (EU) Anti-Tax Avoidance ...
The interest deduction limitation thresholds apply per financial year. Where a financial year contains fewer than 12 months, it is treated as a full financial year. For example, if a collective entity that usually closes its financial year on 31 March decides during 2020 to close its financial ...
Sweden has had targeted interest deduction limitation rules (the Targeted Rules) in various forms since 2009, and in 2019 general EBITDA-based interest deduction limitation rules (the General Rules) were introduced. In 2021, the Swedish government appointed a commission ...
aThe Danish interest deduction limitations consist of the Danish thin capitalisation rules as well as the asset and EBIT limitation tests. 丹麦兴趣扣除局限包括丹麦虚性资本化规则并且财产和EBIT局限测试。[translate]
In addition to a group interest rate limitation, the proposal would introduce increased compliance requirements to safeguard the deductibility of intra-group interest expense. According to these rules, the taxpayer must provide credible evidence that the so-called debt service (which includes i...
You should also bear in mind that since the NID is classified as interest for the purposes of income tax, the interest deduction limitation set out in Article 26(h) of the ITA can also be triggered to disallow the deduction when:a) the risk capital is used to finance ...
For U.S.-based multinational businesses, the Section 163(j) interest expense limitation rules should be applied to their controlled foreign corporations (CFCs) and CFC Groups to calculate Subpart F income, GILTI tested income and income effectively connected with a U.S. trade or business ...