The European Commission has recently published an EU Directive proposal regarding a debt-equity bias reduction allowance (DEBRA) and a limitation of the tax deductibility of exceeding borrowing costs (the proposal). This session will take you through the proposed provisions and generate discussions in relation to their interaction with other provisions.

When
Wednesday, 13 July 2022
Time
14:00 - 16:00
Venue
Online
Speakers
Audrey Azzopardi

EU Proposal to Implement Debt-equity Bias Reduction Allowance (‘DEBRA’)

The European Commission has recently published an EU Directive proposal regarding a debt-equity bias reduction allowance (DEBRA) and a limitation of the tax deductibility of exceeding borrowing costs (the proposal).

This proposal, published 11 May 2022, is one of the Commission’s key actions on corporate tax, as set out in the Communication on Business Taxation for the 21st Century.

The proposal aims to address the disparity in treatment between debt and equity financing by introducing a tax deductible allowance for equity investments over a 10-year period, as well as further limiting the ability to deduct interest on debt investments.

The restriction on deducting debt interest will interact with the existing interest limitation rule (ILR) under Article 4 of the Anti-Tax Avoidance Directive (ATAD).

The proposed rules would apply to taxpayers that are subject to corporate income tax in one or more EU Member States, including permanent establishments of non-EU head offices. However they do not apply to financial undertakings (as exclusively defined in the proposal).

This session will take you through the proposed provisions and generate discussions in relation to their interaction with other provisions.

Members are entitled to a complimentary 6 CPE hours of MIT seminars.

To claim the offer for this webinar select ‘MIT Members – Membership Offer’ as the price option. A participant’s eligibility for the offer claimed is subject to final confirmation by the Malta Institute of Taxation – Terms & Conditions Apply

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2 CPE Core Hours

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Audrey Azzopardi

Audrey is a senior manager within the PwC Malta Tax and Legal line of service.

She is an accountant specialising in taxation of corporate and international tax law. She graduated from the University of Malta in 2005 and prior to joining PwC, she worked in the Assurance Unit of another Maltese audit firm.

Audrey joined PwC in 2009 and over the past years, she has assisted in providing advice to a wide portfolio of local and international clients across a wide variety of industries.

She participates in various in-house seminars and lectures and regularly contributes to the firm’s local and global publications