Ministry of Finance clarification on application of thin capitalization rules in the context of tax treaties
On 20 December 2006, the Ministry of Finance of the Russian Federation issued a private ruling in the form of a letter (No. 03-08-05) dealing with the application of thin capitalization rules in the context of tax treaties. According to this clarification, domestic thin capitalization rules also apply to the interest paid by a subsidiary resident in Russia to its parent c…
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