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新的企业所得税法第四十六条规定,企业从其关联方接受的债权性投资与权益性投资的比例超过规定标准而发生的利息支出,不得在计算应纳税所得额时扣除。(原《企业所得税税前扣除办法》的相关规定为:纳税人从关联方取得的借款金额超过其注册资本50%的,超过部分的利息支出,不得在税前扣除。)这实际上是新税法新增加的有关防止资本弱化的内容。
The new Article 43 of the Enterprise Income Tax Law stipulates that the interest expenses incurred by an enterprise when the ratio of its debt investments and equity investments accepted by its related parties exceed the prescribed standards shall not be deducted when calculating the taxable income. (Formerly, the relevant provisions of “Pre-tax deduction for enterprise income tax” are as follows: If the amount of borrowing obtained by a taxpayer from a related party exceeds 50% of its registered capital, the excess of interest expenses shall not be deducted before tax.) This is actually a new Tax law newly added to prevent the weakening of capital content.