Section 187A — Finance Act 2014: Excess interest treated as a qualifying distribution

Excess interest treated as a qualifying distribution 187A 1 Subsection (2) applies if Conditions A to C in section 187 are met in circumstances where section 174A prevents a claim under section 174.

2 The interest paid under the actual provision, so far as it exceeds ALINT, is treated for the purposes of the Income Tax Acts as a dividend paid by the company which paid the interest (and, accordingly, as a qualifying distribution).