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Russian Court Confirms Interest Withholding Tax Exemption under Cyprus Treaty Only Applies for Beneficial Owners

|Treaty Development|Russia-Cyprus
Russia-Cyprus

The Moscow Federal Arbitration Court has recently issued a decision concerning the beneficial ownership requirement for the enjoyment of the withholding tax exemption on interest under the 1998 Cyprus-Russia income and capital tax treaty.

The case involved Russia-based MDM Bank, which in 2011 and 2012 made interest payments on bonds issued to Cyprus-based MDM Investments Ltd. (MDM Cyprus) and …

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