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Private ruling on beneficial ownership in tax treaties issued

|Approved Changes|Russia
Russia

On 21 April 2006, the Ministry of Finance issued a private ruling No. 03-08-02 (the "Ruling") on the beneficial ownership test for tax treaty purposes.
According to the Ruling, the term "beneficial owner" shall be interpreted from a teleological perspective, i.e. taking into account the objectives and basic principles of a treaty. In this context, the Ruling ide…

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