000			02050nab a2200241 c 4500
999			_c147670 _d147670
003			ES-MaIEF
005			20230609125344.0
007			ta
008			230609t2023 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100			_923574 _aKemmeren, Eric Cornelia Catharina Maria
245		0	_aTaxing interest in the Debtor State as an Alternative to DEBRA _c Eric C.C.M. Kemmeren
500			_aResumen.
520			_aBasically, a company can be financed by debt or equity. The general national tax systems are that interest, the compensation paid for funds put at disposal by means of a loan, are deductible and that the compensation for funds put at disposal by means of equity is not. In this context, the question often arises of whether this different treatment is justified. Or should they be treated (more) the same? The European Commission has proposed a directive to tackle to debt-equity bias by introducing a notional allowance on equity, on the one hand, and a new limitation on interest deduction, on the other hand (DEBRA). This editorial raises the questions of whether the tax treatment of the remuneration paid on loans (interest) by companies and the remuneration on their equity (profits) as proposed in DEBRA is sufficiently based on principles to contribute to a sustainable tax system with regard to company financing, and if not, what an alternative would be that better complies with those principles. The author concludes that DEBRA is another stopgap for flaws in the current tax systems, which has the potential to further distort the capital markets. He suggests an alternative system based on the principle of origin to remove the debt-equity bias.
650		4	_970671 _aDIRECTIVA DEBRA
650			_aIMPUESTO DE SOCIEDADES _945680
650			_aACCIONES _93357
650			_aCAPITAL _933516
650		4	_941769 _aDEDUCCIONES
650		4	_aUNION EUROPEA _948644
773	0		_9169561 _oOP 2141-B/2023/2 _tEC Tax Review _w(IEF)124968 _x 0928-2750 [print] _g v. 32, issue 2, April 2023, p. 44-55
942			_cART