background image
12.2.1. Main Rules

There are no specific thin capitalization rules in Mali. However, the rate of interest paid to shareholders is limited to the loan rate of the Central Bank of West African States (BCEAO) plus three points. Amounts exceeding that rate are non-deductible.

In addition to the above limitation, the Tax Code further stipulates, in relation to transfer pricing, that the Tax Administration is empowered to adjust amounts transferred improperly, including where the transfer is caused by thin-capitalization.