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Notional Interest Deduction

Jan Werbrouck Partner and Brent Springael Associate Brussels office of Benelux law firm NautaDutilh discuss a recent development in Belgian tax law
On 30 June 2005 the law of 22 June 2005 was published in the Belgian State Gazette thereby abolishing the 0.5% tax on capital contributions to Belgian companies and allowing Belgian companies and Belgian branches to deduct from their tax base a fictitious or notional amount of interest based on their adjusted equity capital. Both measures will in principle apply as of 2006.
For Belgian companies and Belgian branches of foreign companies the tax treatment of financing with borrowed funds has traditionally been more favourable than financing with...

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