Interest accrued and written off is not subject to withholding tax – Ministry of Finance clarifications

On 14 November 2013, the Ministry of Finance issued Letter No. 03-08-05/48939 clarifying the withholding tax treatment of the interest accrued and written off in case a Russian company took a loan from a foreign company without a permanent establishment in Russia and the foreign company forgave the interest accrued.
According to article 310 of the Tax Code, the tax on income received by a foreign company from Russia should be withheld and paid to the state budget by the Russian entity (company or…