ruling

Positive ruling on deductibility of interest costs on loans contracted in order to finance capital reduction in case of an ‘over-capitalised’ company

12 March 2019

The Belgian ruling office recently published a positive decision deciding that interest costs related to the intercompany loan are deductible for tax purposes since the costs are borne by the company with the purpose to preserve or generate taxable income. In the case at hand, a factoring company with ‘an excessive amount of equity’ is