The text of Letter No 03-03-04/1/736 issued by the Ministry of Finance on 9 November 2006 has become available.
In the Letter, the Ministry clarified the provisions of Art. 251 of the Tax Code, under which the transfer of assets between legal entities where the shareholding of one of them in the other exceeds 50% is not regarded as taxable income.
The Ministry explained that this provision applies not only to the transfer of assets between a …