Belgium: Interest Deduction Limitation
Belgium has enacted interest deduction limits consistent with the EU Anti-Tax Avoidance Directive (ATAD). As a result, for the purposes of calculating a Belgian Corporate Income Tax (CIT) liability, net interest costs can only be deducted up to the higher of 3 million euros or 30% of consolidated EBITDA (subject to certain grandfathering provisions).
These rules bring Belgium into line with other regimes that have already implemented ATAD. Existing rules regarding interest paid to beneficiaries in low-tax jurisdictions have remained in place.