LETTER OF THE FEDERAL TAX SERVICE OF THE RUSSIAN FEDERATION

of September 3, 2013 No. ED-4-3/15969 @

About accounting for the purpose of the taxation of profit of the amounts of the taxes paid in the territories of foreign states

The Federal Tax Service in coordination with Department of tax and customs and tariff policy of the Ministry of Finance of the Russian Federation (the letter No. 03-03-10/32521) concerning accounting for the purpose of the taxation of profit of the organizations of the amounts of the taxes paid in the territory of foreign states reports of 12.08.2013 the following.

According to article 274 Tax Code of the Russian Federation tax base for the purposes of the taxation of profit of the organizations monetary value of the profit determined according to article 247 Tax Code of the Russian Federation taxable is recognized.

Profit for the Russian organizations for the purpose of the specified Chapter the gained income reduced by the size of the made expenses which are determined according to Chapter 25 "The income tax of the organizations" (article 247 Tax Code of the Russian Federation) is recognized.

According to Item 1 of article 252 Tax Code of the Russian Federation expenses the proved and documentary confirmed costs (and in cases, the stipulated in Article 265 Tax Code of the Russian Federation, losses) performed (suffered) by the taxpayer are recognized. Reasonable expenses are understood as economically justified costs which assessment is expressed in cash.

Expenses any costs are recognized provided that they are made for implementation of the activities directed to income acquisition.

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