Russia Clarifies Gains from the Sales of Shares Deriving Value from Russian Property are Taxable under Treaty with Cyprus from 2017

The Russian Ministry of Finance recently published Letter No. 03-08-05/1593, which clarifies the taxation of capital gains from the alienation by a Cyprus organization of shares in a Russian organization deriving more than 50% of their value from immovable property situated in Russia. According to the letter, under the 1998 Cyprus-Russia income tax treaty as amended by the 2010 protocol, the alienation of such shares deriving value from immovable property in Russia are taxable in Russia from …