Commentary on Sections Overview Overview Section 182: Making of section 182 claims
374.This section provides the basic requirements for the claim. It is based on paragraph 6C(3) to (5) of Schedule 28AA to ICTA.
375.Subsection (3) allows the claim to be made before the calculation of profits has been made by the advantaged person. This allows tax to be deducted from the arm’s length sum rather than the actual sum, thus enabling inward investors to obtain certainty on the consequences of loan financing.