Cross Border Distributions of Liquidated Companies
Guidance Letter 03-08-PZ/9680 covers the issue of taxation of distributions to a non-resident company upon liquidation of a company in Russia when the non-resident is a shareholder. The guidance is in respect to the tax treaty between Russia and Austria, but should be generally applicable for other treaties with relevant provisions.
Under Russian law, any income obtained on distribution of after-tax income or liquidation distributions made to …