Debt interest should be deductible if it is linked to the generation of taxable income. If the rental value ceases to apply, it is logical to limit the deduction of debt interest.
The deductibility of debt interest on consumer loans is already unfamiliar to the system today, because the loan – as the name suggests – is typically used to finance consumption, not to generate income. Lombard loans are often used to finance a securities portfolio. This can result in taxable income from assets, but also capital gains that are tax-free in the case of private assets. Parliament has opted for a rather strict rule limiting the deductibility of debt interest.
The current debt interest deduction is designed as a general deduction. With the reform, debt interest can only be claimed on that part of the assets which is accounted for by rented and leased properties. The nature of the debt (mortgage, lombard loan, consumer credit etc.) is therefore also irrelevant within the scope of the reform. Although it would be possible to create a formal legal link between debts and a property, doing so is virtually impossible from an economic perspective.