When setting up a company in Russia, this raises a question about what options are available to finance an OOO (LLC) and what the benefits each brings. In our article we will attempt to explain the basics.

1. ACCOUNTOR ACCOUNTOR Moscow Stockholm
Sadovnicheskaya nab. 79 Shpalernaya ul. 54 St. Petersburg Oslo
115035 Moscow, Russia 191015 St. Petersburg, Russia Kyiv Copenhagen
+7 495 788 00 05 +7 812 325 82 94 Helsinki Utrecht
moscow@accountor.ru spb@accountor.ru
accountor.ru accountor.ru
When setting up a company in Russia, this raises a question about what options are available
to finance an OOO (LLC) and what the benefits each brings. In our article we will attempt to
explain the basics.
Generally, there are the following options for financing an OOO:
+ Debt financing;
+ Financing on terms similar to equity financing;
+ Equity financing;
+ Transfer pricing (intra-group services).
1. Debt financing
The parent company may grant loans to finance the company. It may also establish certain
level of interest on this loan which is generally considered as a deductible expense for the
Russian subsidiary for profit tax purposes. The amount of deductible interest is, however,
restricted to that level. At your request we would be pleased to further advise you on the
issue of deductible interest.
2. Financing on terms similar to equity financing
The law allows the right for shareholders to extend financing to their Russian subsidiary on
terms similar to equity financing. This financing will avoid the issue of net asset value and
nominal share capital as it does not affect the value of share capital. There are two possible
alternatives to provide financing to an OOO on terms similar to an equity financing:
+ contribution to assets;
+ parent company’s aid.
Financing options for an LLC
in Russia

2. 3. Equity financing
In principle, equity financing is tax neutral as an investment in share capital is not subject to
tax. However, we would like to briefly address the issue of the ratio between net asset value
and nominal share capital.
The law states that a company’s net asset value must always be greater than the company’s
share capital. If the company’s share capital is greater than its net asset value for two
consecutive years (excluding the first financial year), the company will be required to
decrease its share capital to an amount equal to its net asset value. If the company’s net
asset value is smaller than the minimum share capital set by law (RUB 10,000, approx. USD
150), the company will be subject to liquidation (Article 30 (4) Federal Law On Limited
Liability Companies).
4. Intra-group services
In addition to equity and debt financing, you could consider financing an OOO by paying for
services performed by an OOO.
*Please note that in general cross-border transactions, including interest-bearing loans and
service agreements, between related parties may be subject to transfer pricing rules. This
means that you need to consider transfer pricing rules if option 1 (debt financing) or option 4
(a loan) is chosen. The transfer pricing rules require that the prices applied in controlled
transactions should be in line with the prices applied by non-related parties on the market
for comparable transactions under similar economic conditions (arm’s length principle).
Among other things, these rules put an additional administrative burden on Russian
companies trading with their related foreign companies as they require Russian companies
to develop and maintain transfer pricing documentation in certain cases, as well as file
transfer pricing reports with the tax authorities.
At your request we would be pleased to advise you further on transfer pricing and other tax
and legal implications of any of the above options.
Accountor provides “turn-key” services for company registration in Russia. We have been
serving both international and local Russian companies with legal and financial
administration services since 1992 through our offices in Moscow and St. Petersburg, in
which we employ over 200 professionals.
ACCOUNTOR ACCOUNTOR Moscow Stockholm
Sadovnicheskaya nab. 79 Shpalernaya ul. 54 St. Petersburg Oslo
115035 Moscow, Russia 191015 St. Petersburg, Russia Kyiv Copenhagen
+7 495 788 00 05 +7 812 325 82 94 Helsinki Utrecht
moscow@accountor.ru spb@accountor.ru
accountor.ru accountor.ru

3. Contact us today:
Samuli Pesu
Deputy CEO
Mobile: +7 926 710 43 61 /
+358 50 553 20 34
Office: +7 495 788 00 05
Email: Samuli.Pesu@accountor.ru
Pertti Sarosalo
Sales Director Nordics
Mobile: +358 40 590 7603
E-mail: Pertti.Sarosalo@accountor.ru
Daniil Berlizov
Senior Business Development
Manager
Mobile: +7 916 539 68 66
Office:+7 495 788 00 05
Email: Daniil.Berlizov@accountor.ru
ACCOUNTOR ACCOUNTOR Moscow Stockholm
Sadovnicheskaya nab. 79 Shpalernaya ul. 54 St. Petersburg Oslo
115035 Moscow, Russia 191015 St. Petersburg, Russia Kyiv Copenhagen
+7 495 788 00 05 +7 812 325 82 94 Helsinki Utrecht
moscow@accountor.ru spb@accountor.ru
accountor.ru accountor.ru