Court of Appeal: The Notional Interest Deduction does not require substance

On 12 January 2016, the Antwerp Court of Appeal rendered an interim judgement on the Notional Interest Deduction. (a) Facts. In the beginning of 2008, a Finish Group acquired a Russian power plant. It used a Belgian intra-group finance company to structure the acquisition. The Belgian company obtained a loan from the Finish parent company, … Continue reading Court of Appeal: The Notional Interest Deduction does not require substance