Thin capitalization rules | NEWCO - Corporate Services Provider

Net financing costs contribute to determining taxable profit up until the greater of the following limits: 1 million euros or 30% of EBITDA.

Net financing costs that are not deductible under the aforementioned terms can also be considered when determining taxable profit of one or more of the subsequent taxation periods, after net financing costs for this period, taking into account the aforementioned limitations.

Whenever the amount of financing costs deducted is less than 30% of the result before depreciation, amortization, net financing costs and taxes, the unused part of this limit shall be added to the maximum deductible amount up until the 5th period subsequent taxation period.

These rules apply to the permanent establishments of non-resident entities, with the necessary adaptations.