Debt-Financed Acquisitions of Inter-Company Shareholdings – Recent Developments

This article examines the deductibility of interest incurred in financing the acquisition of an inter-company shareholding. In particular, the article outlines the non-deductibility of interest incurred in relation to tax-exempt income, the specific rule that was introduced in 2004 to allow for the deduction of interest incurred for the acquisition of shareholdings, and the exception to the 2004 provision that was introduced effective 1 January 2011 for inter-company acquisitions.