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Nigerian Tax Appeal Tribunal Holds Interest on Related Party Loans Deductible if at Arm's Length

|Approved Changes|Nigeria
Nigeria

In 2013, a Nigerian oil company's claim for the deduction of interest on related party loans was denied by the Nigerian tax authorities based on a provision of the Petroleum Profits Tax Act (PPTA). The denial was based on PPTA section 13(2), which states that a company may not deduct interest on money borrowed from a second company when either company has an interest in the other, both companies have an direct or indirect interest in another company, or both are subsidiaries of another compan…

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