The Federal Arbitration Court of the Moscow decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules. The Federal Arbitration Court of the Moscow Circuit (FAC) decided in Case A41-21630/2013 on 2 September, 2014 that a taxpayer has to apply the thin capitalization rules as the applicable tax treaty does not contain any restrictions on deductibility rules.
Related Posts
Germany unveils anti-tax evasion package with tougher penalties, AI-powered enforcement
Germany's government has unveiled an ambitious 26-point package aimed at strengthening the country's response to tax evasion, financial crime and illicit financial activity through tougher sanctions, enhanced enforcement powers and greater use of
Read MoreGermany announces suspension of double taxation treaty with Russia
Germany has notified Russia that it will suspend the agreement of 29 May 1996 between the two nations for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital, effective from 1 January 2027. The notification was
Read MoreGermany: Bundesrat approves ordinance to expand Minimum Tax Act framework
Germanyβs Federal Council (Bundesrat) approved the amendment of the regulation on the application of the minimum taxation law (Mindeststeuer-Bericht-Verordnung β MinStBV) on 10 July 2026. The measure expands the framework under the Minimum
Read MoreGermany updates 2026 basis for negotiating double taxation agreements
Germany has published the 2026 update to its basis for negotiating Double Taxation Agreements (DTAs) covering taxes on income and on capital. The document serves as the Federal Government's starting point for treaty negotiations with foreign states
Read MoreRussia: State Duma approves first reading of employee incentive tax bill
Russia's State Duma has approved, in the first reading, a Ministry of Finance bill that would introduce tax incentives for administrators of employee incentive programmes by extending an existing tax exemption. This announcement was made on 7
Read MoreGermany gazettes tax advisory reforms, anti-profit shifting measures enter into force
Germany published the Ninth Act Amending Provisions in Tax Consultancy Law and Tax Law in the Official Gazette on 2 July 2026. The legislation introduces extensive reforms to the regulation of tax advisors and tax advisory organisations while
Read More