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A securitisation fund manager has enquired whether the variable fee, which offsets the fund's accounting result, should be treated as financial income or expense for the purpose of applying the deductibility limit under Article 16 of the Corporate Income Tax Act. The Directorate General for Taxes (DGT) ruled that such a fee must follow the nature of the items it offsets.
This ruling clarifies the classification of variable fees in securitisation funds, affecting how they are treated for corporate tax deductibility purposes under the net financial expense rules.
The tax team reviews your specific situation.
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