The Specific Interest Deduction Limitation Rule prohibits deduction of Interest expenditure incurred on a loan obtained directly or indirectly from a Related Party for payment of Dividend or profit distribution to a Related Party, if the Related Party receiving the Interest is not subject to Corporate Tax, or a similar tax in a foreign country at a rate of at least 9%, on the Interest. Such Interest will not form part of Net Interest Expenditure when applying the General Interest Deduction Limitation Rule.
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