3. Final remarks

Consultation on a Debt Equity Bias Reduction Allowance

sufficient degree of anti-abuse measures in the area of debt-financing. We would therefore invite the European Commission to conduct a review of the regulations already in place.

Eliminating any bias towards any particular kind of financing precisely would also put an end to incentives for tax structuring options. Last, but not least, a uniform and consistent system throughout the EU would prevent arbitrage between tax systems in the EU, moreover, all other (non-EU) cases are sufficiently addressed by existing CFC-legislation. If the European Commission nevertheless considers such measures to be necessary, we suggest focusing on specific and targeted anti-abuse provisions instead of narrowing the scope of DEBRA.

3. Final remarks

BDI encourages the European Commission to improve the neutrality between debt and equity financing. In our view, a preferential treatment of new corporate equity or new profits would be the most eligible solution as it is the only way to address the debt equity bias without creating other distortions.