S.L. 123.189 ст. 10Payment to transparent subsidiary.

The principal taxpayer may make a payment to a transparent subsidiary for any loss, deduction or allowance which is transferred to the principal taxpayer in terms of rule 4(1) or which would have been a loss, deduction or allowance of the transparent subsidiary had it not been part of the fiscal unit of the principal taxpayer, which payment shall not exceed the amount of such loss, deduction or allowance and any such payment shall not be taxable in the hands of the recipient company and shall not be tax deductible for the payor.