Russian Tax Service Provides Instruction on Beneficial Ownership for Holding Companies Under Tax Treaties
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 concer…
Continue Reading