Il modello ACE in Europa: dalle origini alla proposta di direttiva DEBRA

This paper aims to analyse the origins and developments of the ACE (Allowance for Corporate Equity) Model, focusing on the rise and fall of the DEBRA directive proposal. On 11 May 2022, the European Commission – to promote a harmonized tax environment that places debt and capital financing on an equal footing across the EU – presented a legislative proposal for a Debt-Equity Bias Reduction Allowance (DEBRA), a version of the ACE Model. The proposal extends, on a European dimensional scale, a corrective measure initially developed at a national level for corporate financial structures unbalanced towards debt. However, it does not escape the cyclical trend that characterizes the debate on the ACE and has now been dropped.