The author, in this note, examines the new interest deduction limitation rule in article 57(b) of the Income Tax Act, comparing it with the recommended best practice approach of the OECD in BEPS Action 4 and commenting on its shortcomings.
The author, in this note, examines the new interest deduction limitation rule in article 57(b) of the Income Tax Act, comparing it with the recommended best practice approach of the OECD in BEPS Action 4 and commenting on its shortcomings.