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A private equity association seeks to coordinate the non-deductibility under article 15.h) LIS (group financing expenses for acquiring group shares) with the general 30% operating profit limit under article 16 LIS and the additional debt acquisition limit under article 16.5 LIS. The DGT establishes the order: first exclude non-deductible expenses under article 15.h); then apply successively the additional limit under article 16.5 and the general limit under article 16.1. It details the mechanics of reducing acquisition debt from 70% to 30% over eight annual instalments and outlines transitional provisions preserving the deductibility of participative loans and pre-June 2014 restructuring operations.
Clarifies the deductibility rules for group financing expenses and acquisition debt, ensuring compliance with the 30% operating profit cap and introducing a phased reduction of acquisition debt, while maintaining transitional deductibility for pre-2014 transactions.
The tax team reviews your specific situation.
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