The Supreme Arbitration Court of the Russian Federation (the "Court") has decided that when the tax authorities only partially challenge the VAT recovery of companies, then the tax authorities must immediately reimburse companies for the unchallenged part of VAT.

Additionally, the companies will typically not have to wait until the tax authorities have decided to deny VAT recovery for the disputed part, as the tax authorities will be obliged to pay interest to the companies on any part of the delayed reimbursement of VAT.

[Decree No. 14883/10 of the Presidium of the Supreme Arbitration Court of the Russian Federation, dated 12 April 2011]