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Guidance on Thin Capitalization Rules for Loans from Unrelated Russian Lenders with Related Foreign Guarantors

|Approved Changes|Russia
Russia

Russia's Ministry of Finance recently issued guidance on the application of thin capitalization rules when a foreign company holds 20% or more of the equity of a Russian company, and that foreign company acts as a guarantor for a loan to the Russia company by a non-related Russian lender.

Under the law, the debt is considered controlled debt, and the deductibility of the interest payments is l…

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