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Belgian Court of Cassation Holds Notional Interest Deduction May Not be Claimed in Abnormal Economic Circumstances

|Approved Changes|Belgium
Belgium

A 24 May 2019 judgment of Belgium's Court of Cassation (Supreme Court) was recently published on whether a structure established to take advantage of the Belgian notional interest deduction (NID) may be considered abnormal and thus limiting a NID claim. The case involved a Finnish parent that took over a Russian company through its Swedish subsidiary. The takeover was financed with the insertion of a Belgium company, and involved a EUR 3 billion loan from the Finnish parent to the Belgian com…

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