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vi. It has been directed that the Independent Business of an Exempt Person shall be liable for Article 30.
vii. Qualifying Infrastructure Projects
• Net Interest Expenditure incurred by a Qualifying Infrastructure Project (QIP) Person in relation to a Qualifying
Infrastructure Project shall not be subject to the General Interest Deduction Limitation Rule.
• QIP Person - A Resident Person that is responsible for the provision, maintenance, or operation of a QIP or Carries
on any other activity that is ancillary to, or facilitates the provision, maintenance, or operation of a QIP. QIP is
defined thereunder.
7. Thin Capitalization: Practical Considerations and Challenges
Thin Capitalisation poses significant impact for many taxable persons whereby the taxable income and tax liability
may lead to substantial cash flows for the businesses. It is therefore highly important that a thorough analysis of
facts and scenarios is undertaken to avoid any surprises that may affect the conduct of day-to-day operations and
adversely affect a Group’s global tax planning and strategy.
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UA E TAX UPD ATE NEWSLET TER ISSUE 04 - July 2024