(1) This section applies to:
(a) interest paid by a person in respect of an offshore borrowing of the person; or
(b) interest consisting of gold paid by a person in respect of an offshore gold borrowing of the person;
if, when the borrowing took place, the person was an offshore banking unit (whether or not the person is still an offshore banking unit when the interest is paid).
(1A) However, this section does not apply to:
(a) interest paid on or after 1 January 2024; and
(b) interest consisting of gold paid on or after 1 January 2024.
(2) Tax is not payable in accordance with this Division in respect of interest to which this section applies.