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Changes as a result of Anti Tax Avoidance Directive


If interest is not deductible as a result of the generic interest deduction restriction, this inter-est can be carried forward unlimited to the future. To prevent any improper use, an anti-abuse measure has been included in the corporation tax. Provisions have also been included to arrange any concurrence between carried forward interest based on the generic interest deduction restriction and the tax group rules. In addition, the provisions on demergers, mergers, administrative reorganisations or realignments are supplemented for situations where claims exist on carried forward interest based on the generic interest deduction restriction.