This judgment constitutes confirmation of previous case law in which the interest deduction on shareholder loans for acquisitions was also not accepted.
The A-G has concluded, on various grounds, that the rate for interest on tax due of 8% cannot be maintained and should be reduced. It is now up to the Supreme Court to decide on this matter.
These judgments are very important for the practice, because the Supreme Court addressed the applicationof the anti-abuse provision in holding structures.
