The Ministry of Finance Letter No. 03-01-18/53941, issued on 10 December 2013, clarifies the rules to determine the income for controlled transactions purposes. The Ministry of Finance specified that transactions defined in article 105.14 of the Tax Code should be considered as controlled only if the income derived from those transactions exceeds certain thresholds. According to section 9 of article 105.14 of the Tax Code, income for the purposes of the controlled transactions test is calculated as the sum of the income from operations with one related party in one calendar year.
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Russia’s draft DTAs with Belgium and China
Russia’s draft DTAs with Belgium and China
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