how do you apply TIN capitalisatio rule on foreign loan

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how do you apply TIN capitalisatio rule on foreign loan | TCircle

how do you apply TIN capitalisatio rule on foreign loan

Original Law Text

&ldquoNotwithstanding any other provision of this Act, for the purpose of ascertaining the profit of any company for any period...”

Section 27(1):

No deduction shall be allowed for the purpose of ascertaining the profits of any company in respect of—

Capital employed as improvements.

Any sum recoverable under an insurance or contract of indemnity.

Simplified Explanation

This section explains which business expenses may not be allowed as deductions when calculating your taxable profit.

Non-business expenses may be disallowed
Unsupported claims may be rejected
Capital improvements are not deductible here

Corporate Tax

how do you apply TIN capitalisatio rule on foreign loan

when a company borrows from a foreign entity either related party or guaranteed by a related party. how do you account for the interest on the loan . what are the conditions and application

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