Together with our colleagues across the WTS Global network, Svalner Atlas Advisors contributed to the updated Interest Limitation Rule (ILR) Study 2026, covering all EU Member States, Norway, Switzerland, the United Kingdom and the United States.

Although the Interest Limitation Rule has become firmly embedded in the European tax landscape following the introduction of ATAD, the study shows that its practical application remains far from uniform across jurisdictions.

The study highlights several important differences between countries, including:

• variations in the calculation of tax-adjusted EBITDA;
• differences in safe harbour thresholds and their practical application;
• country-specific implementation choices, such as lower EBITDA percentages or specific group rules; and
• ongoing discussions and legal challenges regarding compatibility with EU law in certain jurisdictions.

These differences can materially impact financing structures and cross-border tax positions. In practice, we regularly see how local implementation and interpretation of the ILR influence structuring considerations and tax outcomes.

A thorough understanding of both the rules and the evolving case law is therefore essential for multinational groups operating across multiple jurisdictions.

You can access the full WTS Global ILR Study 2026 here.

Would you like to discuss the implications for your organisation? Please feel free to contact Gerbrand Hidding or Roemer Schimmelpenningh.