关联企业间借款利息税前扣除政策分析

An Analysis on Pre-tax Deduction of Loan Interest among Associated Enterprises

企业关联方借款利息支出的税前扣除问题,一直是企业特别是涉外企业所得税征管中的焦点之一。本文详细分析了执行关联企业间借款利息税前扣除政策要把握的几个政策问题。

The issue of pre-tax deduction of loan interest from associated counterparts of enterprises has been one of the focal issues in income tax administration, especially concerning foreign-related enterprises. This paper provides a detailed analysis on some main points in implementing the pre-tax deduction policy of loan interest among associated enterprises.