Some double tax agreements contain a rule that allows affiliated entities to enjoy the benefits of the agreement (reduced rate) if the interest paid abroad is in line with the market price. When the interest exceeds the market value, affiliated entities may apply the reduced rate of tax resulting from the double tax agreement only to the market value of the interest. Interest paid abroad in the amount exceeding the market value is already taxed in accordance with the provisions of the Corporate Income Tax Act (Personal Income Tax Act).