OrbitaxRussia Clarifies Treaty Benefits for Interest Income Paid to Recipient That is Not the Beneficial Owner Including MLI Impact
|Treaty Development|Russia-Korea, Rep of
The Russian Ministry of Finance recently published a guidance letter concerning the taxation of interest payments made by a Russian resident to the Bahrain branch of a South Korean bank where the Korean bank is the actual beneficial owner.
The letter notes that interest income paid by a Russian resident to a foreign legal entity is subject to corporate tax in Russia, which should be withheld …
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