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A securitisation fund manager has enquired whether variable fees, which neutralise 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 DGT has ruled that such fees must be included in the calculation of net financial expenses to the extent that they correspond to the financial nature of the income and expenses they offset.
The tax team reviews your specific situation.
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