Under the EU Anti-Tax Avoidance Directive (ATAD or the directive concerning an interest limitation rule) as transposed in Cypriot income tax law, certain “excessive” borrowing costs are deductible in the tax period in which they are incurred but only up to 30% of the taxpayer’s earnings before interest, tax, depreciation and amortisation (EBITDA), as adjusted.
The directive’s legal provisions transposed into Cypriot tax law include certain “opt outs” in relation to:
Read a September 2019 report prepared by the KPMG member firm in Cyprus
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