The Russian Ministry of Finance recently published Letter No. 03-08-05/14396, which clarifies treatment of excess interest under the thin capitalization rules, including when the status of debt as controlled has changed at the time the interest is paid. Russia's thin capitalization rules apply when a taxpayer has controlled debt exceeding a debt-to-equity ratio of 3:1 (12.5:1 for banks and leasing companies). With the new thin capitalization rules that apply from 1 January 2017 ({News-2016-02…