1. A Taxable Person's Net Interest Expense shall be deductible up to (30%) (thirty percent) of the Taxable Person's accounting earnings before interest, taxes, depreciation and amortization (EBITDA) for the relevant Tax Period, excluding any Exempt Income under Article (22) of this Decree-Law. 2. A Taxable Person's Net Interest Expense for a Tax Period is the amount of the Interest Expense incurred during the Tax Period in addition to the amount of any Net Interest Expense carried forward under Clause (4) of this Article, which exceeds the taxable Interest income derived during that same period. 3. The limitation under Clause (1) of this Article shall not apply where the Net Interest Expense of the Taxable Person for the relevant Tax Period does not exceed an amount specified by the Minister. 4. The amount of Net Interest Expense that is not deductible under Clause (1) of this Article may be carried forward and deducted in the subsequent (10) ten Tax Periods in the order in which the amount was incurred, subject to Clauses (1) and (2) of this Article. 5. Interest Expense that is not deductible under any other provision of this Decree-Law shall be excluded from the calculation of Net Interest Expense under Clause (2) of this Article. 6. Clauses (1) to (5) of this Article shall not apply to the following Persons: a. A Bank. b. An Insurer. c. A natural person undertaking a Business or Business Activity in the State. d. Any other Person as may be determined by the Minister. 7. The Minister may issue a decision to specify the application of Clauses (1) and (2) of this Article to a Taxable Person that is related to one or more Persons through ownership or control and they are obligated under applicable accounting standards to have consolidated financial statements.
Interpretation and application must be checked against the official text and current version.