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Tax News Russia: Double taxation treaty
By the letter of the Ministry of Finance No. 03-00-RZ/16236 of 9.04.14 it is established that on the basis of the double taxation treaty only the beneficial owner of the corresponding income abroad can use privileges.
So far for the application of the lowered tax rate the tax residence certificate was enough (for example, for the recipient of dividends). However it is still not clear how to prove in practice that the person is the beneficial owner of the income.
Article supplied by Russia Consulting
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