ATAD Implementation in Belgium: An Analysis of the New Interest Limitation Rule

In implementing the ATAD Interest Limitation Rule, Belgium remained as investment-friendly as permissible, making use of the de minimis threshold of EUR 3 million, the possibility to share unused interest deduction capacity with Belgian group members and to carry forward any unused interest deduction capacity indefinitely. There is, however, some complexity in the rules, a high compliance burden, and some red tape associated with a transfer of unused interest capacity to affiliated Belgian companies.