LETTER OF THE FEDERAL TAX SERVICE OF THE RUSSIAN FEDERATION

of December 28, 2012 No. ED-4-3/22506 @

Concerning submission to tax authorities of tax declarations on the income tax of the organizations by the member of the consolidated group of taxpayers at receipt of the income from equity in other organizations (dividends), the tax on which is withheld by the tax agent (source of payment of the income), by it

The Federal Tax Service directs for data and use in work the letter of the Ministry of Finance of the Russian Federation of 11.12.2012 N 03-03-10/135 concerning submission to tax authorities of tax declarations on the income tax of the organizations by the member of the consolidated group of taxpayers at receipt of the income from equity in other organizations (dividends), the tax on which is withheld by the tax agent (source of payment of the income), by it. Bring this letter to subordinate tax authorities and taxpayers.

Appendix

LETTER OF THE MINISTRY OF FINANCE OF THE RUSSIAN FEDERATION

of December 11, 2012 No. 03-03-10/135

The department of tax and customs and tariff policy considered the letter concerning submission to tax authorities of tax declarations on the income tax of the organizations by the member of the consolidated group of taxpayers (further - KGN) in case of receipt of the income from equity in other organizations (dividends), the tax on which is withheld by the tax agent (source of payment of the income), by it, and reports the following.

According to provisions of article 278.1 of the Tax Code of the Russian Federation (further - the Code) the consolidated tax base is determined by KGN based on the amount of all income and expenses and the amount of all expenses of participants of KGN considered for the purpose of the taxation by the income tax of the organizations taking into account the features established by this Article.

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