The Ministry of Finance clarified in the Letter of 19 August 2010 (N 03-03-06/1/559) the moment for the determination of the debt-to-equity ratio for thin capitalization rules. The thin capitalization rules provide for a debt-to-equity ratio of 3 to 1. The Russian company has to determine the ratio at the end of each reporting period, which is either a month or a quarter. According…