OrbitaxTransactions concluded between entities which incurred losses may qualify as controlled – Ministry of Finance clarifications
|Approved Changes|Russia
On 1 November 2013, the Ministry of Finance issued Letter No. 03-01-18/46763 clarifying in which cases the transactions concluded between entities which incurred losses should be considered as controlled transactions for the purposes of transfer pricing regulations.
The Ministry of Finance referred to article 105.14 of the Tax Code which provides, among other conditions, that transactions …
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