The Russian Ministry of Finance recently published Letter No. 03-08-05/78852 concerning the beneficial ownership requirements for tax treaty benefits. According to the letter, from 1 January 2017, for a foreign resident to obtain the benefits of a tax treaty (lower rates or exemption on income), the foreign resident must not only provide proof of its residence in the relevant foreign jurisdiction to the Russian payer (tax agent), it must also provide proof that it has the actual right to rece…