Thin Capitalization

Tax

Turkish: Örtülü Sermaye

Short definition

Thin capitalisation is the slice of related-party debt that exceeds a statutory debt-to-equity (or similar) cap. Interest on the excess is not deductible; the shield is cut and the slice may be treated as a hidden distribution.

Detailed explanation

The cap and the definition are jurisdictional; there is no universal multiple. Bank debt is often treated differently; intra-group and guaranteed structures trigger the cap.

An earnings-stripping cap can sit beside it. If WACC and target leverage ignore the cap, after-tax Kd is optimistic.

Why it matters for the CFO

Intra-group FX debt can look cheap and then lose its shield under thin-cap; all-in then approaches the cost of equity.

How to read it

The cap is a tax D/E, not the accounting D/E. Guarantees and back-to-back can change related-party status.

Related calculators

Güven Sayılgan’s writing on this topic

Read these first

What to learn next

  1. Deductibility
  2. Tax Shield
  3. Transfer Pricing (TP)
  4. Debt-to-Equity (D/E)
  5. After-Tax Cost of Debt

Definitions are educational. They are not investment, credit or tax advice.