On 8 March 2015, Russia enacted Federal Law No. 32-FZ, which amends the country's thin capitalization rules. Although a previous draft had included a new definition for controlled debt extending the rules to foreign interdependent parties (affiliates), the changes as enacted do not included the extension and the basic concept of a controlled transaction remains the same. In addition, the exemption for third-party banks as included in the previous draft is also removed from the final law. The …