| 释义 |
thin capitalization
An arrangement in which a company is incorporated (typically in another jurisdiction) with a small share capital and financed by a large loan from its parent company. The arrangement is often designed to give tax relief on the interest payment on the loan, whereas no relief would be available on dividends paid on shares. In the UK a special tax regime is applied in certain instances of thin capitalization, so that excessive interest paid on the loan is treated as if it were a non-tax-deductible dividend (Taxation (International and Other Provisions) Act 2010 s 152). |