1. No deduction shall be allowed for Interest Expense incurred on a loan obtained, directly or indirectly, from a Related Party in respect of any of the following transactions: a. A dividend or profit distribution to the Related Party. b. A redemption, repurchase, reduction or return of capital to the Related Party. c. A contribution in the capital of the Related Party. d. The acquisition of an ownership interest in a Person who is a Related Party or becomes a Related Party following the acquisition. 2. Clause (1) of this Article shall not apply where the Taxable Person can demonstrate that the main purpose of obtaining the loan and carrying out the transaction referred to under Clause (1) of this Article is not to gain a Corporate Tax advantage. 3. For the purposes of Clause (2) of this Article, no Corporate Tax advantage shall be deemed to arise where the Related Party is subject to Corporate Tax or a tax of a similar character under the applicable legislation of a foreign jurisdiction on the Interest at a rate not less than the rate specified in paragraph (b) of Clause (1) of Article (3) of this Decree-Law.
Interpretation and application must be checked against the official text and current version.