A guidance letter from the Russian Federal Tax Service was recently issued to the heads of the FTS departments and the chiefs of the FTS inspectorates on the application of Russia's new general anti-avoidance rule (GAAR), which was introduced in July 2017 ({News-2017-07-28/A/4-previous coverage}). The guidance clarifies that in applying the GAAR, the tax authorities must ensure that the evidence proves the intentional participation of the audited taxpayer in the purposeful creation of condit…