The tax authority issued a ruling regarding the deductibility of interest paid to a related Belgian company benefiting from the notional interest regime. On 4 September 2019, the French General Directorate of Public Finance clarified that tax treatment of interest deductions taken by a French company on interest payments to a related Belgian company that benefits from the Belgian notional interest rate scheme. In accordance with the French Law, interest on total amounts paid to an affiliate enterprise outside France is only deductible if a minimum rate of tax applies to the relevant income abroad.
World Tax Brief: September 2019
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