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13.2. Thin-capitalization and other Restrictions to Interest Deduction

Deduction in respect of interest paid on loans / amounts provided by a foreign-controlled resident company (except a bank) is not allowed, if the debt-equity ratio exceeds 1.5:1 at any time during the relevant tax year.

Foreign-controlled resident company means a resident company in which 50% or more of the shares are held, directly or indirectly, by a non-resident company (with or without associates).