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July 30, 2026
This article introduces a cap on interest deductions to combat base erosion, aligned with OECD/BEPS Action 4. A Taxable Person's Net Interest Expenditure is deductible only up to 30% of its EBITDA (accounting earnings before interest, tax, depreciation, and amortisation), excluding any exempt income. Net Interest Expenditure disallowed under this cap can be carried forward and deducted in the subsequent 10 Tax Periods. The rule does not apply if net interest is below a de minimis threshold set by the Minister. Banks, insurance providers, and natural persons are exempt from this limitation rule.
Chapter 9 - Deductions
Article 30 - General Interest Deduction Limitation Rule
[GTL Notes]
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