Is the loan interest of affiliated enterprises deducted in full if it does not exceed the standard proportion?

Hello! According to the information you provided, our reply is as follows. If the information is incomplete, please communicate with us again! The Notice of State Taxation Administration of The People's Republic of China on Printing and Distributing the Implementation Measures for Special Tax Adjustment [Trial] No.2 stipulates: Article 85 The interest expenses that cannot be deducted when calculating the taxable income mentioned in Article 46 of the Income Tax Law shall be calculated according to the following formula: the interest expenses that cannot be deducted = all related party interests actually paid in the current year ×( 1- standard ratio/ratio of related debts to assets), among which, The standard ratio refers to the ratio stipulated in the Notice of the Ministry of Finance of State Taxation Administration of The People's Republic of China on Tax Policy Issues Concerning the Pre-tax Deduction Standard for Interest Expenses of Related Parties of Enterprises (Caishui [2008] 12 1No.). The proportion of related debt refers to the proportion of debt investment accepted by an enterprise from all its related parties (hereinafter referred to as related debt investment) to the equity investment accepted by the enterprise according to Article 46 of the Income Tax Law and Article 119 of the Implementation Regulations of the Income Tax Law. Related creditor's rights investment includes creditor's rights investment guaranteed by related parties in various forms. Article 86 The specific calculation method of related debt-to-capital ratio is as follows: related debt-to-capital ratio = sum of average related debt investments in each month of the year/sum of average equity investments in each month of the year, in which: average related debt investments in each month = (book balance of related debt investments at the beginning of the month+book balance at the end of the month)/average equity investments in each month = (book balance of equity investments at the beginning of the month+book balance at the end of the month) /2 Equity investments are the owner's equity amount listed in the enterprise's balance sheet. If the owner's equity is less than the sum of paid-in capital (share capital) and capital reserve, the equity investment is the sum of paid-in capital (share capital) and capital reserve; If the sum of paid-in capital (share capital) and capital reserve is less than paid-in capital (share capital), equity investment is paid-in capital (share capital). Approximate algorithm does not deduct = 240 * (1-(2/3)/100%) = 800,000 yuan, and allows deduction = 240-80 = 1.6 million yuan. The advance payment of 2.4 million yuan is the interest calculated according to the bank's interest rate for the same period. Welcome to consult again!