"Thin" capitalisation (under-capitalisation): new rules

Download PDF Pepeliaev Group advises that on 29 January 2016 the State Duma adopted a federal law  which significantly changes the rules for taxing interest on debt obligations to related parties and/or on debt obligations raised with such parties involved (the so-called "thin" capitalisation, or "under-capitalisation" rules). The law also clarifies many issues which may arise in connection with law enforcement practice where these rules are applied.