LLC M has outstanding debt

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LLC M has outstanding debt on debt to company L in Switzerland. The specified debt is more than four times the difference between the amount of assets and the liabilities of LLC “M” for the last number of the tax period.
In relation to LLC M, the Interdistrict Inspectorate for the largest taxpayers conducted a desk tax audit for the period 2009-2011. based on the results of which a decision was made on prosecution and additional taxation of income tax in the amount of 200,490,000 rubles.
One of the grounds for invalidating the allocation of the accrued interest on debt obligations to the expenses of LLC “M” for the period 2009-2011 was the conclusion of the tax authority on the need to apply the provisions of paragraph 2 of Art. 269 ​​of the Tax Code of the Russian Federation, which regulates the procedure for calculating interest in relation to controlled debt.
The taxpayer, considering the opinion of the tax authority erroneous, when applying to the Arbitration Court of the Sverdlovsk Region referred to Art. 24 agreements of 11/15/1995 and of 05/12/1998, believing that these provisions virtually exclude the possibility of applying paragraph 2 of Art. 269 ​​of the Tax Code of the Russian Federation when accounting for interest on controlled debt.
Taking into account the norms of the current tax legislation, prepare for the taxpayer a reasoned explanation on this issue.

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