Circular Letter regarding the “grandfathering” provision included in 30% EBITDA rule
On 11 September 2019, the Belgian tax administration published a Circular Letter regarding the grandfathering provision that is included in the recently introduced interest deductibility limitation (i.e. 30% EBITDA rule). The 30% EBITDA rule includes a grandfathering provision for loans that have been issued before 17 June 2016 and that have not been “fundamentally modified”