Russia's Federal Tax Service has published Letter No. ED-4-13/15696@ of 8 August 2019, which provides instructions to tax authorities on the determination of the actual right of holding companies to income from sources in Russia under a tax treaty (i.e. beneficial ownership).
The letter notes that the FTS continues to develop uniform approaches in the framework of tax control measures concerning the unlawful application of taxpayers and tax agents of the preferential treatment provided und…