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Thin capitalisation: applying the 12.5 coefficient on leasing-related income

25 January, 2021

In a case involving OOO De Lage Landen Leasing, the Russian Supreme Court has overturned lower court decisions adopted in favour of the tax authorities and sent the case for a re-trial. The dispute concerned the application of the 12.5 thin capitalisation coefficient by the leasing company to income generated from related activities. In the audited period, only companies engaged exclusively in leasing activity were eligible to apply the 12.5 coefficient. The Company and the tax authorities disagreed on the issue of exclusiveness.

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Raisa Aleksakhina

Raisa Aleksakhina

Partner PwC Legal, Head of Dispute Resolution with Public Authorities, PwC Russia

Tel: +7 (495) 232 5429

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