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The article is dedicated to the application of Russian thin capitalisation rules in the light of the Russian tax treaties. The author analyses the non-discrimination provisions set up in the OECD Model Tax Convention and the Russian tax treaties, the Russian court practice on the question concerned, as well as certain provisions of the new Model Tax Convention.
thin capitalisation rules, non-discrimination, OECD Model Convention, deductibility of interest, reclassification of interest in dividends