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ARTICLE · 05 FEBRUARY 1997

Exchange Gains And Losses

RussiaAntitrust/Competition Law
(Tax News Reporter - Week Ended 4 February 1997)

We have received oral confirmation from the tax authorities that exchange gains and losses will be treated as before 5 December 1994, i.e. as non-realisational income or expenditure which adds up to or decreases the gross profit and is taxed accordingly. Doubt could have arisen from the fact that Government Regulation No. 552 no longer contains the provision (which was repealed by Government Regulation No. 661 of 1 July 1995) that exchange gains are considered as non-realisational income and exchange losses as non-realisational expenditure, but the tax authorities have indicated that the new profits tax instruction will include some explicit wording on this issue. Exchange gains and losses may occur in two situations. "Realised" exchange gains or losses arise if there is a time lag between recording a sale or a purchase and the moment of receipt or payment of the foreign currency and the exchange rate of the currency has changed

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