The Russian Ministry of Finance recently released Guidance Letter No. 03-03-06/1/108990, which clarifies amendments to the loss restriction rules introduced by Federal Law No. 259-FZ in relation to IT companies qualifying for a 0% corporate tax rate. The reduced rate is provided under the "ultra-low tax regime" for IT companies and was reduced from 3% to 0% during the period 2022 to 2024. Taxpayers are generally allowed to carry forward tax losses to future periods except in certain cases, including specified cases where the taxpayer applies a 0% corporate tax rate. The specified cases do not include the 0% corporate...