Causes
Under certain legal provisions, the deduction of interest for corporate income tax purposes may be limited. These restrictions may apply in cases involving:
- Fiscal reclassification of debt as equity
- Loans deemed anti-profit shifting
- Low-interest, long-term loans
- The generic earnings stripping rule
- Hybrid loans
These rules can become particularly complex when structuring loans or dealing with international tax matters. We’ll help you identify opportunities and assess potential risks.