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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 DGT has ruled that such a fee must be included in the calculation of net financial expenses to the extent that its origin lies in the difference between income and expenses of a financial nature.
This ruling clarifies the classification of variable fees for securitisation funds, affecting how the net financial expense limit is calculated for tax purposes.
The tax team reviews your specific situation.
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