The company created a subsidiary, gave a loan. People work and turn.

The tax comes:

Your financial performance is bad. In such a situation, no one except the related persons would give you a loan. So there is no business purpose and interest on the loan can not be included in tax expenses.



Well fuck them, the costs have been reduced, the fine paid - work on.

Worked well.

Next year comes the tax:

Your financial performance is very good. You do not need a loan at all.

So there is no business purpose and interest on the loan can not be included in tax expenses!