Under the recent opinions issued by the Slovak tax authorities, interest on acquisition loans are considered to be tax non-deductible. This treatment applies not only to the acquisition SPV itself but also to the situation when the merger of the Acquisition SPV and the Target is completed.
Obviously, the above opinions have a significant impact on all LBO (leveraged buyout) transactions and debt-push down strategies.
However, is the conclusion of Slovak tax authorities correct? We do not think so!
We will discuss this topic in more detail within our presentation on the 3. Conference on International Taxation that is organised by the Slovak Chamber of Tax Advisors on 7 November 2019.