Netherlands: Guidance on scope of ATAD interest deduction limitation rules

Effective July 30, 2025

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october 22, 2025

The State Secretary for Finance on July 29, 2025, published a decree providing guidance on the scope of the interest deduction limitation rules under the Anti-Tax Avoidance Directive (2016/1164).

Key clarifications include the treatment of loans, bonds, and extendible loans, as well as the inclusion of hedging instruments in interest income and expenses.

The decree—effective July 30, 2025—specifies that the tonnage tax scheme does not affect the minimum deduction allowance and confirms the per-element approach for adjusted profit determination.


For more information, contact a KPMG tax professional in the Netherlands:

Luc van der Voort | vandervoort.luc@kpmg.com

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