In the Letter № 03-01-18/7-134 as of 01.10.2012 the Ministry of Finance of Russian Federation clarified that for recognition of persons as related the influence, which is exerted due to participation of one person in the capital of another person/entity in accordance with the agreement signed or due to another opportunity to determine other persons decisions, to be taken into accounts.

The influence to be taken into accounts regardless the fact whether one person exerts it independently or jointly with this person’s related persons. At the same time, clause 2 Article 105.1 of the Russian Tax Code does not provide the recognition of the entity and its employees as related persons.

It is important to note that according to clause 7 Article 105.1 of the Tax Code, the court has a right to recognize persons as related due to other criteria not provided in clause 2 of this Article if relations between these persons have signs indicated in clause 1 Article 105.1 of the Tax Code. 

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