¿Regla de subcapitalización o earnings stripping rule?: Análisis evolutivo y comparativo de las normas que limitan la deducción de gastos financieros y su enfoque en el Perú

Abstract

In 2018 one of the most important tax reforms in recent years took place. As part of this reform, the well-known thin capitalization regime stipulated in Article 37 of the Income Tax Law was modified. Therefore, in this paper, we aim to unravel the foundations and antecedents of this anti-avoidance rule, as well as its characteristics and shortcomings according to the legal and economic situation that the country is going through.