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.