Usage of thin capitalization rule in the Russian Federation

In the modern economy, there exist various ways to avoid taxes. One of them is based on getting large loans from foreign owners or their affiliates in order to pay interest, not dividends. The essence of this method is to include interest payments in the expenses of the organization to reduce the tax base for income tax. In this article, the main methods of elimination such methods of reducing the tax burden using the thin capitalization rule in the Russian Federation were considered, as well as judicial practice is given. At the end of the article, it is concluded that courts have to pay attention to the specific details of each dispute when solving cases with signs of thin capitalization, and not be guided only by a formal approach.