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.
Court decides that the provision of tax treaties between Germany & Russia do not obstruct the application of thin capitalization rules
October 27, 2014
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