Home  Journals  International Accounting  2(200) - 2012 January

Controlled debt or features of the taxation of interest income

Available online: 16 January 2012

Subject Heading: Taxation

JEL Classification: 

Article is devoted controversial issues of taxation of interest income paid by a Russian organization, the borrower of a foreign or a Russian organization, the debt to which the rules of paragraph 2 of Art. 269 of the Tax Code recognizes the «controlled». The author has given a comparative analysis of the mechanism of regulation of controlled debt to Russian laws and international agreements signed by Russia. The article provides the official position of financial agencies and courts on controversial issues.

Keywords: interest income of a foreign organization, controlled debt, capitalization coefficient, the marginal value of interest

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ISSN 2311-9381 (Online)
ISSN 2073-5081 (Print)

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