How will the thin cap rules work in 2017?

Dec 29, 2016

The amended thin capitalisation rules become effective starting from 1 January 2017. Let’s review the key changes.

Please also note that the “freeze” of currency exchange rates for the purposes of the rules is prolonged until 31 December 2019. This measure was adopted in order to mitigate the impact of rise in foreign exchanges against the Russian Rouble for purposes of thin capitalisation rules. The “freeze” applies to “old” loans, provided that the terms of debt obligations remain unchanged over the whole period when the new rules are in effect. Thus, for calculating controlled debt and net assets amounts, the exchange rate as of 1 July 2014 is used. These temporary rules reduce the number of cases when interest expenses are reclassified into dividends.

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David John
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Partner, CIS Tax and Legal Leader
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