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The DEBRA Directive and its interplay with Pillar 2 Dieter Bettens

By: Bettens, Dieter.
Material type: ArticleArticleSubject(s): FISCALIDAD INTERNACIONAL | SEGUNDO PILAR (OCDE) | IMPUESTO DE SOCIEDADES | TIPO MÍNIMO GLOBAL | DIRECTIVA DEBRA | INTERES | DEDUCCIONES | INCENTIVOS FISCALES | UNION EUROPEA In: Intertax v. 50, n. 12, December 2022, p. 907-922Summary: The EU Commission proposed a directive on 11 May 2022 to provide for a more equal treatment between debt and equity for tax purposes (Debt-Equity Bias Reduction Allowance, DEBRA). This article sets out the basics of the DEBRA directive. Furthermore, it recalls certain essential building blocks of the Pillar 2 directive that are necessary for the subsequent analysis. The last section examines the impact that the DEBRA directive will have on the application of the Pillar 2 directive.
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Resumen.

The EU Commission proposed a directive on 11 May 2022 to provide for a more equal treatment between debt and equity for tax purposes (Debt-Equity Bias Reduction Allowance, DEBRA). This article sets out the basics of the DEBRA directive. Furthermore, it recalls certain essential building blocks of the Pillar 2 directive that are necessary for the subsequent analysis. The last section examines the impact that the DEBRA directive will have on the application of the Pillar 2 directive.

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