A 5 June 2019 decision of the Court of North Holland has been published regarding the treatment of interest income subjected to Russia's thin capitalization rules. The case involved a Dutch company that had provided loans amounting to approximately EUR 9 million to its Russian affiliate during 2007 and 2008. When the loans were repaid, the Russian tax authorities applied the thin capitalization rules to disallow the deduction of approximately EUR 3 million, which was reclassified as dividends and subject to 15% withholding tax. With the reclassification of the income as dividends by Russia, the Dutch company claimed that the...