On 27 February 2013, the Ministry of Finance issued Letter No. 03-08-05/5690 clarifying the tax treatment applicable to interest paid on loans taken for the purposes of acquisition of shares and capital contribution in foreign companies. Also, the application of the participation exemption regime to dividends distributed by a company whose shares were aquired with borrowed funds was clarified.
A Russian limited liability company acquired shares in several Russian companies and in a compa…