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A securitisation fund manager has enquired whether the variable fee, which neutralises the fund's accounting result, should be treated as financial income or financial expense for the purpose of applying the deductibility limit under Article 16 of the Corporate Income Tax Act. The Directorate General for Taxes (DGT) has ruled that the portion of the fee corresponding to the difference between financial income and expenses must be included in the calculation of net financial expenses.
This ruling clarifies the accounting treatment of variable fees in securitisation funds, specifically regarding how they affect the calculation of net financial expenses for tax deductibility purposes under the Corporate Income Tax Act.
The tax team reviews your specific situation.
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