On 31 January 2019, the Chamber approved the advancement of the implementation date of the new interest limitation rule (30% EBITDA rule). The law will become effective after it is signed by the King and published in the Official Gazette.
Concretely, this means that the Belgian 30% EBITDA rule will enter into force retroactively as from assessment year 2020, i.e. financial years starting on or after 1 January 2019, which is in line with the targeted implementation date under ATAD I. The specific technical details and mechanics of the rule were already approved with the law of 30 July 2018 and are further explained in PwC’s earlier communication.
Note that a Royal Decree is still expected to define amongst others the concept of “interest” when calculating the net borrowing cost and to allocate the “EUR 3-million threshold” over the different entities of a qualifying group. Up until today, these Royal Decrees have not yet been finalised.
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