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12.2. Thin-capitalization and other Restrictions to Interest Deduction

Interest charges paid to related parties are not deductible to the extent:

  • the interest rate exceeds the rate of the Central Bank of West African States (BCEAO) plus 2 percentage points; or
  • the payer’s debt (including from 2 January 2019 loans granted by shareholders to their holding companies) exceeds 100% of its paid-up capital; or
  • the interest expense exceeds 30% of EBITDA; or
  • the interest is paid in remuneration of debt with a maturity of 5 years or more; or
  • capital of the debtor company is not fully paid up.