In the Official Gazette of 17 December 2012, Decree No. BLKB2012/1642M of 4 December was published, which provides for modifications to Decree No. CPP2006/2514M of 5 July 2007 on the thin capitalization regime. The most important changes are summarized below. Group ratio – consolidated accounts requirement Based on article 10d(6) of the Corporate Income Tax Act (CITA) resident companies may in the annual tax return request to compare its own debt/equity with the debt/equity ratio of the group of companies to which it belongs. Excessive debt would then be the part of the annual average debt of the company which...