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Restriction of deduction in respect of money borrowed before basis period relating to year of assessment 2008

Income Tax (Deductible Borrowing Costs) Regulations 2008

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Where a discount on debt securities referred to in item 3 in the Schedule or premium on debt securities referred to in item 4 in the Schedule is incurred by any person on any debt securities issued before the basis period relating to the year of assessment 2008, only such amount of the discount or premium attributable to the year of assessment 2008 and subsequent years of assessment as determined —(a)in accordance with the formulawhere Ais the number of days between the first day of the basis period relating to the year of assessment 2008 and the date the discount or premium is incurred by the person (both dates inclusive);Bis the number of days between the date the debt security was issued and the date the discount or premium is incurred by the person (both dates inclusive); andCis the total amount of discount or premium incurred by the person; or(b)where it is just and reasonable in the circumstances of any particular case, on such other basis as the Comptroller thinks fit,shall be deductible.

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