Сhanges to the thin capitalization rules
On 15 February 2016, the President signed the Federal Law No. 25-FZ, which amends Article 269 of the Russian Tax Code – the section of the code defining the concept of controlled debt.
The Law introduces significant changes to controlled debt and the range of transactions controlled for the purposes of applying thin capitalization rules. The Law also specifies the procedure for calculating the debt-to-equity ratio required to acknowledge debt as controlled, the capitalization coefficient and interest limitation rules for profit tax purposes. For more detail on these changes, please see our LT in Focus of 11 February 2016.