Below, we explain the measures against profit tax evasion set out in the Income Tax Act and result from Council Directive (EU) 2016/1164 (Anti-Tax Avoidance Directive, ATAD) and Council Directive (EU) 2017/952 (ATAD2).

Handbook “Specifications upon taxation with income tax”

What are surplus borrowing costs

The residual borrowing cost is the amount by which the deductible borrowing costs of a resident company exceed interest income and other taxable income which is economically equal (subsection 2 of § 542 of the Income Tax Act). Interest income and other economically equivalent taxable income is income arising from debt claims.

The calculation of surplus borrowing cost is done a cash basis, i.e. the borrowing cost is compared with cash-based interest income. The surplus borrowing cost is if, based on the income statement, the cost of borrowing on a cash basis is greater than the interest income.

Interest income is a so-called mirror image of the same types of income that are defined as the cost of loan use for the borrower.

Last updated on 08.01.2025

Last updated: 13.11.2025

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