The actually implemented since the restriction rate has not been determined by the Council of Ministers President until now. This time with the Presidential Decree No. published in the Official Gazette dated . the rate regarding the financial expense restriction has been determined as to be applied in the taxation periods starting from . . Accordingly of the interest and similar payments excluding interest and similar payments added to the investment cost corresponding to the portion exceeding the equity capital from foreign sources used by the taxpayers within the scope will not be accepted as expenses and the said expenses will not be considered as expenses that are not legally accepted on the declaration will need to be taken.
On the other hand regarding the application issues such as the definitions of equity and foreign resources the date on which resource comparison will be made situations where maturity differences are included in the price to be paid or the practice in businesses Ecuador Mobile Number List that have financial income along with financing expenses create hesitations. In addition the term investment has not been defined for the expense and cost elements to be added to the investment cost outside the expense limitation and it has not been determined whether the value added tax incurred due to the expenses that will not be taken into account in determining the profit as expenses.
That are not legally accepted within the framework of the financing expense limitation will be deducted. The same provisions were included in the legal regulation that was the basis for implementation in previous years between and and regarding the mentioned issues With the repealed Corporate Tax Law General Communiqu numbered the concept of investment was defined as any kind of depreciable economic asset investment with or without incentive certificate and With the repealed Corporate Tax Law General Communiqu numbered it was deemed appropriate to deduct the value.