The Russia Federal Tax Service (FTS) has issued letter No. SD-4-3/6181@ of 4 April 2019 concerning the recognition of losses as a result of the liquidation of a foreign subsidiary. In particular, the letter concerns a Russian company that had acquired 100% of the shares in a company resident in Cyprus in 2012 for approximately RUB 1.5 billion. The Russian company subsequently decided to liquidate the Cyprus subsidiary, which was completed in 2016. In connection with the liquidation, the Russi…