A russian subsidiary of British American Tobacco was found by the russian tax administration to have overpaid interest on loans from an affiliate in the Netherlands.
The Court ruled in favor of the tax administration
Russia vs British American Tobacco, Aug. 2014, Russian High Court
Posted on |
By Courts of Russia
Category: Financial Transactions, General Anti-Avoidance Rules (GAAR) | Tag: British American Tobacco, Intra-group loan, Loan, Netherlands, Thin Capitalisation (Thin Cap)
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