The Draft Law No. 675906-6 regarding the introduction of changes to article 269 of part 2 of the Tax Code in respect to the meaning of the concept of controlled indebtedness has been submitted to the State Duma on 16th December 2014. A representative from the Finance Ministry has recommended that amendments will be made to the method for the thin capitalization ratio for foreign currency debts to exempt the devaluation impact after 1st July 2014. This exemption is expected to be an interim measure and effective until the end of 2015. Under the proposed changes, debt may be recognized as controlled if a Russian borrower has a foreign direct or indirect shareholder. Under No. 376-FZ of 24, a foreign company that is Russian tax resident (Article 246.2 of the Tax Code) is considered as a Russian organization for profits tax purposes with effect from 1st January 2015 and becomes subject to the thin capitalization rules. According to the December draft, the ratio of controlled debt to a borrower’s equity is to remain 3:1 (12.5:1 for banks and leasing companies). A threshold of 90% for income is introduced for leasing companies below which the 12.5:1 ratio cannot apply. For each draft, the above changes are proposed to enter into force on 1st January 2016.
Related Posts
Russia clarifies registration rules for subdivisions, foreign organisations
The Russian Federal Tax Service has issued clarifications on changes to the rules governing the registration of
Read More
Russia: Government extends export duty on oilseed flax until 2028
The Government of Russia has extended the export customs duty on oilseed flax leaving the country for destinations
Read More
Russia proposes VAT, SME tax changes
Russia’s State Duma has received draft law No. 1331250-8, submitted on 2 September 2026, proposing to reduce the
Read More
Russia expands tax monitoring access for legal successors from September 2026
Russia has expanded access to its tax monitoring regime from 1 September 2026, allowing legal successors of companies
Read More
Russia: FTS clarifies Pillar Two corporate tax rules for MNE groups
Russia has introduced special rules for calculating corporate income tax for members of international groups of
Read More
Russia: FTS to introduce updated 3-NDFL tax return form from September 2026
Russia’s Federal Tax Service (FTS) will introduce an updated 3-NDFL tax return form (KND 1151020) from 1 September
Read More