Notional interest on interest-free loans to a non-viable subsidiary cannot be taxed under the real income principle.
Notional interest on interest-free loans to a non-viable subsidiary cannot be taxed under the real income principle. Issue Whether the tax authorities are justified in adding and taxing notional interest under Section 5 on long-term interest-free advances given to a non-viable subsidiary company, when both entities agreed not to charge interest and judicial consistency supports… Read More »