OrbitaxTreaty between Russia and Cyprus – Russian Appeal Court decided on applicability of beneficial owner and economic substance requirements
|Treaty Development|Cyprus; Russia
On 5 December 2012, the Appeal Court heard case No. ?40-60755/12-20-388 between the Russian branch of Eastern Value Partners Ltd. (EVP Co.), a company resident in Cyprus, and the tax authorities. The tax authorities denied the applicability of the Cyprus - Russia Income and Capital Tax Treaty (1998) on the grounds that the conditions regarding beneficial ownership and economic subst…
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