Will there be any exemptions from the General Interest Deduction Limitation Rules?
Banks, Insurance Providers, and individual taxpayers are exempt from the provisions of the General Interest Deduction Limitation Rule. Consequently, these entities are not obliged to take into account the de minimis threshold or their adjusted EBITDA when deducting their Net Interest Expenditure. Interest expenses incurred by these categories of taxpayers will be treated similarly to other expenses, and they will be deductible if they comply with the standard regulations of the Corporate Tax Law, such as being incurred during the course of their taxable business activities.
Moreover, deductions for Interest expenses related to the financing of specific long-term infrastructure projects designed for the benefit of the UAE are not subject to the restrictions outlined in the General Interest Deduction Limitation Rule, provided these projects meet specific conditions.
Furthermore, the General Interest Deduction Limitation Rule incorporates a grandfathering provision, exempting loan agreements entered into prior to December 9, 2022, from the application of these rules. This exemption applies as long as the interest payments on these loans adhere to the terms and conditions as they existed on that particular date.
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