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Article 80 serves as an anti-avoidance measure for asset acquisitions. It mandates that if the recorded capital expenditure for an asset exceeds the amount that would have been incurred in an open market (arm's length) transaction, the excess portion must be excluded from the asset's cost for tax purposes. This prevents taxpayers from artificially inflating the value of assets—particularly in related-party transactions—to claim higher depreciation deductions and reduce their taxable income. By enforcing market-value standards, the Law ensures that tax relief is only granted on legitimate, commercially justified investment costs.
Article 80
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