Addressing the Debt Bias: A Comparison between the Belgian and the Italian ACE Systems (June 2014)

european commission

This paper reviews the experiences of Belgium and Italy with ACE-type systems of corporate taxation. The comparison focusses on the definition of the base for the computation of the allowance and the anti-avoidance framework to tackle abuses. It is argued that the Italian system, with its incremental feature and a comprehensive anti-avoidance framework targeting transactions between related parties, seems a more viable solution for an ACE reform aimed at addressing the debt bias in the corporate sector.