In 2013, a Nigerian oil company's claim for the deduction of interest on related party loans was denied by the Nigerian tax authorities based on a provision of the Petroleum Profits Tax Act (PPTA). The denial was based on PPTA section 13(2), which states that a company may not deduct interest on money borrowed from a second company when either company has an interest in the other, both companies have an direct or indirect interest in another company, or both are subsidiaries of another company. The oil company appealed the denial based on PPTA section 10(1)(g), which states that interest...