Recently, the Ministry of Finance published Letter No. 03-03-06/1/22382 issued on 17 June 2013 clarifying the tax treatment applicable to interest that may qualify as dividends in the case of loan agreements concluded between related parties According to the Tax Code, any positive difference between the interest calculated by a resident debtor in a controlled debt transaction with a non-resident creditor and the maximum permitted deductible interest expense qualifies as dividends, which are subject to a withholding tax at the rate of 15% according to the Tax Code, unless the applicable tax treaty provides otherwise. Article 10 of the Russia...