Clarifications on Russia's Beneficial Ownership Requirements for Treaty Benefits
Russia's Ministry of Finance recently issued Letter No. 03-00-RZ/16236, which clarifies the condition for beneficial ownership when claiming tax treaty benefits for passive income (dividends, interest, royalties). The letter states that in order to be considered a beneficial owner, the entity must not only be entitled to receive the passive income, but must be a direct beneficiary with the power …
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