Treaty between Russia and Germany – Russian MoF clarifies whether interest expenses are tax deductible under the tax treaty
Recently, the Ministry of Finance published Letter No. N03-08-05/48897 issued on 15 November 2013 clarifying the tax deductibility of interest payments made by a Russian company to its German parent company under the Germany - Russia Income and Capital Tax Treaty (1996).
According to the Tax Code, interest charged in respect of any kind of debt obligation is tax deductible provided the amount of i…