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Controlled debt


Controlled debt — unpaid debt specified in subitem 2 of item 2 of this article is considered controlled debt for the taxpayer - a Russian organization, in an amount not exceeding the amount of unpaid debt under a comparable debt obligation specified in subitem 2 of item 8 of this article1.

Controlled debt — unpaid debt of the taxpayer - a Russian organization under debt obligations not specified in item 2 of this article, if it is established that the ultimate purpose of payments under such debt obligations is to make payments to organizations specified in subitems 1 and 2 of item 2 of this article2.

  1. Tax Code of the Russian Federation, as amended on 2020-05-21, Article 269, paragraph 12 // Official Gazette of the Russian Federation. 2000. No. 32. Item 3340. ↩

  2. Tax Code of the Russian Federation, as amended on 2023-04-28, Art. 269, para. 13 // RSZ RF. 2000. No. 32. Art. 3340. ↩

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