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Changes to thin capitalization rules in Russia

On 15 February 2016 Federal Law No. 25-FZ was adopted and published, changing the thin capitalization rules (Article 269 of the Tax Code).

The new rules are harmonized with the tax concept of related persons (in Article 105.1 of the Tax Code) and reflect several positions developed in the court practice. In addition, a few important exceptions from the rules are introduced – for financing raised from banks, on capital markets and for intragroup loans within the Russian Federation.

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