Russia - Russian Thin Capitalization Rules: Are They Compatible with Russian Tax Treaties?
- B. Bruk
- European Taxation, 2010 (Volume 50), No 11
- 4 October 2010
Russian tax law provides for a number of limitations on the deductibility of interest payable on loans by Russian companies. Apart from general limitations, there are specific thin capitalization rules aimed at combating excessive debt financing by multinational groups of their Russian subsidiaries. This article examines the compatibility of these rules with Russian tax treaties.