On 17 September 2013, the Ministry of Finance issued Letter No. 03-08-05/38346 regarding the deductibility of interest on a loan obtained by a permanent establishment in Russia belonging to a foreign entity.
The Ministry of Finance referred to article 268 of the Tax Code specifying that the provisions limiting the deductibility of the interest payments related to loans obtained from related parties should apply only to taxpayers qualifying as Russian entities. Consequently, those rules do …