Belgium has published Circular 2021/C/87 of 5 October 2021, which provides guidance on the application of the 30% of EBITDA interest deduction limitation introduced from 1 January 2019 in compliance with the EU Anti-Tax Avoidance Directive (ATAD). One of the key aspects of the guidance concerns the grandfathering rules in respect of "old" loans entered into before 17 June 2016, which provide t…