TerraLex - Article - Loans from Foreign Sister Companies May be Subect to Russian Thin Capitalization Limitations

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Loans from Foreign Sister Companies May be Subect to Russian Thin Capitalization Limitations - Court of Appeal Rules

While under literal interpretation of the Russian law the foreign sister company loans are not regarded as controlled debt and not subject to thin cap limitations, the new decision of the Russian court may amend this practice. Under the decision, where the foreign sister company role is "technical", under substance over form approach the thin cap limitation may also apply to loans from foreign sister companies

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Authored by:

Mr. Roustam Vakhitov
Leading Expert, LL.M., International Taxation
Pepeliaev Group

Reviewed by:

Dr. Rustem Ahmetshin
Senior Partner
Pepeliaev Group

Mr. Denis Schekin
Senior Partner
Pepeliaev Group

Posted:June 21, 2010

Related topics:Private Equity, Mergers and Acquisitions / Divestitures, Real Estate, Taxation, General Interest, Real Property, Franchising

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