In Income Tax Law No. 7092. Article 9 bis: A maximum deductibility for net interest expenses of twenty percent (20%) of the earnings before interest, taxes, depreciation and amortization (Uaiida) is established for each tax period. Article 9 Non-deductible expenses. Paragraph m) Expenses associated with hybrid asymmetries made by the taxpayer to related parties abroad, when such expenses do not generate taxable income or generate exempt income for said related party, or when these expenses are also deductible for the related party domiciled abroad of Income Tax Law No. 7092 Of the Income Regulations Article 19: Limitation on the deduction of non-banking interest. For the purposes of calculating the maximum deductible amount for net interest expenses of twenty percent (20%) of earnings before interest, taxes, depreciation and amortization (EBITDA) for each tax period, the taxpayer must have duly identified in its accounting records the bank interest expenses and other concepts, provided for in the third and sixth paragraphs of article 9 bis of the Law, as well as those that are not. Article 20 of the Income Regulations.- Presumptive net income and financing contracts. In every loan contract or transaction that involves financing, regardless of its nature or name, if a written document exists, it is presumed, unless proven otherwise, that there is net interest income, which must be calculated at an interest rate no less than the highest annual active interest rate set by the Central Bank of Costa Rica or, in the absence of this, with the average of the annual active interest rates of the banks of the National Banking System. This presumption also applies when a lower interest rate is stipulated than that which, according to the Central Bank of Costa Rica, corresponds to the type of transaction in question, or when it has been expressly agreed that there is no interest whatsoever. Evidence to the contrary is not admissible for the presumption established when there is no written document. The Administration may apply the presumption referred to in Article 10 of the law if financing is provided, even when there is no loan contract. For the purposes of Article 10 of the law, financing is understood to be any action or operation that generates funds that allow the recipient to carry out its normal activities, using its assets as collateral or as negotiable instruments, or through the issuance of securities or other documents or commercial instruments. Decree 43198