As part of the 2017 US Tax Reform, a Base Erosion and Anti-Abuse Tax (BEAT) was introduced in the Internal Revenue Code under Section 59A with the aim to combat eroding of US tax base through related-party payments of interest, royalties and management fees. The Internal Revenue Service (IRS) issued proposed Regulations on BEAT mid-December 2018 with a consultation period of two months. On 19 February 2019, the EBF presented the US Treasury with a comment letter emphasizing the detrimental effects of BEAT for European banks. The EBF points out in particular that the exception for interest paid on intercompany funding held in the U.S., which is a welcomed relief for interest paid on certain total loss-absorbing capacity (TLAC) securities, does not extend to similar securities issued by non-U.S. corporations nor does it capture other regulatory-driven funding. In addition, the BEAT applies to a portion of the interest expense that is attributed by a foreign bank to its U.S. branch in accordance to U.S. tax regulations and treaties.
The EBF is the voice of the European banking sector, bringing together national banking associations from 45 countries. The EBF is committed to a thriving European economy that is underpinned by a stable, secure and inclusive financial ecosystem, and to a flourishing society where financing is available to fund the dreams of citizens, businesses and innovators everywhere.
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