Application of the new provisions in Article 269 | KPMG | RU

Application of the new provisions in Article 269 of the Russian Tax Code

Application of the new provisions in Article 269

On 8 March 2015, the President of the Russian Federation signed Federal Law No. 32-FZ

On 8 March 2015, the President of the Russian Federation signed Federal Law No. 32-FZ

On amendments to Part Two of the Russian Tax Code, introducing, inter alia, amendments to Article 269 of the Russian Tax Code.


On 8 March 2015, the President of the Russian Federation signed Federal Law No. 32-FZ On amendments to Part Two of the Russian Tax Code, introducing, inter alia, amendments to Article 269 of the Russian Tax Code. This has created many questions on how the Article is to be applied, especially when it comes to determining interest rates on intra-group liabilities, as currently there is no clear approach.

 

KPMG professionals therefore prepared this information letter together with its analysis of the provisions in Article 269, as well as recommendations on how to apply the provisions when seeking to recognise income/expenses on debt obligations.

 

We hope that this letter will be helpful to you. KPMG will be glad to discuss with you in more detail any particular challenges you face, or to discuss how we can provide your organisation with comprehensive support with transfer pricing and general corporate tax issues.

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