Requalification of interest as dividends in the case of transfer of loan receivables – Ministry of Finance clarification
On 5 August 2013, the Ministry of Finance published Letter No. 03-03-06/1/27682 issued on 16 July 2013 clarifying the conditions of requalifying the interest as dividends when the interest payments are made by a Russian corporate borrower to a foreign creditor particularly when the loan is assigned to a new creditor.
In 2007, a Russian corporate borrower took a loan from a Cypriot creditor t…
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