From 1st March 2014, interest and royalty payments to certain related parties are not deductible for tax purposes if the recipient corporation is not subject to tax due to an exemption; is subject to a nominal or specific tax rate of less than 10% on the interest or royalty income; or is subject to an effective tax rate of less than 10% due to a specific tax regime. An exception applies for payments to entities meeting the EU law privileges for risk capital measures.
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PGA Highlights: February 2014
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