Recently, the Russian Ministry of Finance (MoF) published Letter No. 03-08-05/49380 issued on 18 November 2013 clarifying the tax treatment applicable to interest paid by a Russian company to the Dutch branch of a Taiwanese bank.
The Ministry of Finance referred to article 1 and article 3 of the Netherlands-Russia Income and Capital Tax Treaty (1996) (the Treaty), which provide that persons that a…