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Thin capitalisation rules

Rules that restrict deductibility of interest charged on foreign controlled debt. The rules inter alia apply to loans to a Russian legal entity from a foreign legal entity if the foreign entity owns, directly or indirectly, more than 20% of the Russian entity’s charter capital. The deductibility of interest is restricted to the extent that the controlled debt exceeds net assets by more than three times, or 12.5 times in the case of banks and leasing companies.