Deduction of interest paid to a minority corporate shareholder: arm's length rate allowed

Article 14 of the 2026 budget act amends paragraph I of Article 212 of the General Tax Code: interest paid by a company subject to corporate tax on sums made available by a company that is its shareholder, even without controlling it, is deductible up to the rate the borrower could have obtained from independent financial institutions, if higher than the maximum rate of Article 39 of the Tax Code. This exception was previously reserved for interest paid to related companies.