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Clarifications whether debt forgiveness represents taxable income

|Treaty Development|Russia
Russia

Recently, the Ministry of Finance issued Letter 03-03-06/1/3094, clarifying the corporate income tax implications when a parent company forgives the debt owned by its subsidiary.

A Russian joint stock company (Company) took a loan from a foreign legal entity. In its turn, the loan was further assigned to another foreign legal entity that is fully owned by the Company (the initial debtor). T…

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