Les avantages anormaux ou bénévoles non déductibles des pertes de l'exercice
Auteur | Martin Van Beirs |
Si la rÈcente rÈforme de l'impÙt des sociÈtÈs avait notamment pour objectif une rÈduction des taux d'imposition, cette rÈduction devait Ítre neutralisÈe, au point de vue budgÈtaire, par diffÈrentes mesures dites de compensation.
Parmi ces mesures figure une modification substantielle apportÈe ‡ l'article 207, alinÈa 2, du Code des impÙts sur les revenus (CIR), lequel renvoie ‡ l'article 79 du CIR.
Pour rappel, l'article 207, alinÈa 2, du CIR visait ‡ interdire l'utilisation, par un contribuable, de ses pertes antÈrieures - en principe fiscalement dÈductibles - pour soustraire ‡ la taxation les bÈnÈfices provenant d'avantages anormaux ou bÈnÈvoles consentis par une entreprise liÈe, la notion d'avantages anormaux ou bÈnÈvoles devant s'entendre de la mÍme faÁon que dans le cadre de l'article 26 du CIR.
Dans ce rÈgime, les pertes antÈrieures ne pouvaient Ítre imputÈes sur l'avantage anormal, puisque l'article 207 se rÈfÈrait expressÈment aux "dÈductions prÈvues aux articles 199 ‡ 206", ce dernier visant uniquement "les...
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