Enforcement Rules of the Income Tax Act Article 34

In a profit-seeking enterprise operated by sole proprietorship or partnership, the loan borrowed by the proprietor or the partner shall all be considered dealings of capital owners, and shall not be listed as interest.
中文原文 所得稅法施行細則第34條
凡獨資或合夥經營之營利事業,資本主或合夥人所借貸之款項均應以資本主往來論,不得列支利息。

English translation for reference only; the Chinese text prevails. Not legal advice.