Treaty between Russia and Spain – Russian MoF clarifies tax treatment applicable to interest payments
Recently, the Ministry of Finance issued Letter 03-08-05/6369, clarifying the tax treatment applicable to interest payments based on the Russia-Spain Income and Capital Tax Treaty (1998).
A Russian limited liability company entered into a 5-year loan agreement with its Spanish parent company that holds 100% in the capital of the Russian subsidiary. Based on the loan agreement the Russian s…
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