On 3 April 2008, the Ministry of Finance published Circular AOIF No. 14/2008 on the combating of abuse with respect to the application of the notional interest deduction. Details are set out below.
Background
From 2006, companies that are subject to the tax on non-residents may, if their fiscal year corresponds to the calendar year, deduct a notional interest expense from their taxable profits. The deduction is based on the company's equity, i.e. its share capi…