Source: WFR 2017/125, p. 792-798
Author: Remmel van Dijk
The European Central Bank has been offering a negative deposit facility interest rate since 2014. With a negative interest rate, roles are reversed and debtors receive an interest payment from creditors. This negative interest rate appears to be more than a temporary situation. Interbank Euribor rates are also negative for example. The author saw this as sufficient reason to investigate whether corporate income tax is prepared for a negative interest rate.
In this article, he specifically addresses the potential impact on interest deduction limitations, including the ATAD earnings-stripping measure, which is still to be introduced. The author also examines the impact on the calculation of the second credit limit.