1. It is
understood that an entity that is a resident of Russia and of which at least 10 per cent of the statutory capital is owned by residents of Canada, or a permanent establishment of a Canadian resident carrying on activities in Russia, shall, in computing
its profits, deduct interest on loans
, whether paid to a bank or another person and without regard to the period of the loan, provided the amo
unt of the interest does ...[+++] not exceed the amount that would have been agreed upon between independent persons.