Provisional Measure 472, published in the Official Gazette of 16 December 2009, introduced the so-called "thin capitalization rules" in the tax system.
According to these rules, interest payments would only be tax-deductible if a certain "debt-equity" ratio is met. The ratio varies depending on whether the lender is resident or not (i) in a tax haven, or (ii) in a jurisdiction that provides for a "beneficial tax treatment", as defined by Law (collectively refer…