Limitation on interest deduction restricts related party interest over an EBITDA based threshold, with carryforward limits.

A new provision restricts deductibility of interest paid to associated non-resident lenders by Indian companies and permanent establishments: interest exceeding the lesser of thirty per cent of EBITDA or interest payable to associated enterprises is treated as excess interest and disallowed. Debts guaranteed by or funded via associated enterprises are deemed issued by associated enterprises. Banking and insurance businesses are excluded. Undeducted excess interest may be carried forward up to eight assessment years, and key terms associated enterprise, debt, and permanent establishment are defined for application.

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