The Russian Ministry of Finance recently issued a guidance letter from 2014 which clarifies the treatment of loss carryforwards when a company becomes a member of a consolidate tax group directly or as the result of a merger. The key points of the letter are summarized as follows:
When a company become a member of a consolidated group, any net operating losses carried forward from periods prior to becoming a member of the group may not be utilized to reduce the group's tax base. The same res…