Official Letter 4815 / TCT - CS issued on October 18, 2016 and Official
Letter 4975 / TCT - CS issued on October 26, 2016 are about No - interest
or Low - interest Loan Taxable Income.
The tax authorities were granted the right to estimate taxable income and
to impose taxes when companies do loans without interest or at a lower
interest rate than market rates. However, these Official Letters do not
specify concrete ways to calculate deemed taxable income.
In practice, the tax authorities are supposed to estimate with reference
to interest rates of similar transactions at major banks of each company.