According to Article 41, Paragraph 1 of the Tax Code of the Russian Federation, income is defined as an economic benefit received in cash or in kind, provided that such benefit can be measured and to the extent that it can be evaluated. Income is determined, among other things, in accordance with Chapter 25 of the Tax Code, which regulates corporate income tax.
Chapter 25 of the Tax Code does not establish a method for determining or valuing material benefit arising from an interest-free loan.
Under Article 250, Paragraph 8 of the Tax Code, non-operating income includes, among other things, income received in the form of property (works, services) or property rights provided free of charge, except for the cases specified in Article 251 of the Tax Code.
According to the official position of the Ministry of Finance of Russia, receiving an interest-free loan does not create non-operating income for the taxpayer. This approach is also supported by court decisions, including a ruling of the Presidium of the Supreme Arbitration Court of the Russian Federation.
This position is reflected in the Letters of the Ministry of Finance of Russia dated March 13, 2025 No. 03-12-11/24830 and March 23, 2017 No. 03-03-РЗ/16846.