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Treaty between Russia and US – Russian MoF clarifies tax treatment applicable to interest that may qualify as dividends

|Treaty Development|Russia; United States
Russia; United States

Recently, the Ministry of Finance published Letter No. 03-03-06/1/22382 issued on 17 June 2013 clarifying the tax treatment applicable to interest that may qualify as dividends in the case of loan agreements concluded between related parties

According to the Tax Code, any positive difference between the interest calculated by a resident debtor in a controlled debt transaction with a non-resi…

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