OrbitaxOrbitax

Ministry of Finance clarification on application of thin capitalization rules in the context of tax treaties

|Treaty Development|Russia-Netherlands
Russia-Netherlands

On 20 December 2006, the Ministry of Finance of the Russian Federation issued a private ruling in the form of a letter (No. 03-08-05) dealing with the application of thin capitalization rules in the context of tax treaties. According to this clarification, domestic thin capitalization rules also apply to the interest paid by a subsidiary resident in Russia to its parent company resident in the Netherlands.

Domestic thin capitalization rules apply only…

Continue reading with a Pro Subscription

Unlock full Orbitax Tax News content, including a historical database of tax news, alerts, and analysis from our network of tax experts, all tailored to your company footprint. Now includes Orbitax XatBot AI Tax Assistant.

Free trial available. Cancel anytime. Free Orbitax account required.

Already a Pro or Pro+ subscriber? Sign in to Orbitax to continue reading.