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July 30, 2026
This article provides a targeted anti-avoidance rule for related-party financing. It disallows a deduction for interest expenditure on a loan from a Related Party if the funds are used for specific transactions, such as paying a dividend, repurchasing shares, or making a capital contribution to another Related Party. An exception applies if the taxpayer can demonstrate the main purpose was not to gain a Corporate Tax advantage. A tax advantage is not considered to arise if the Related Party receiving the interest is subject to tax on that income at a rate of 9% or higher.
Chapter 9 - Deductions
Article 31 - Specific Interest Deduction Limitation Rule
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