The President has signed a new law on 8th March 2015 for changing article 269 of the Russian Tax Code. Precisely, the provisions of extending thin capitalization rules to foreign affiliates and bank loans are excluded from the new law. Under Russian tax law, the main concept of thin capitalization remains unchanged. According to amended article 269, a new way will be taken to calculate interest income and costs on debt compulsions that come from controlled transactions. Once the law enters into force, Taxpayers subject to these provisions will have to recalculate the thin capitalization ratio for company for the first 9 months of 2014 and for 2014 as a whole and compute the limits on controlled credits and loans from the beginning of 2015.
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