Clarifications for justifying the GDR holders residence for treaty purposes

On 17 September 2012, the Ministry of Finance issued the letter No. 03-08-05 specifying the list of documents that may be used to confirm residence of the global depository receipt holders ("GDR holders") for tax treaty purposes.
To claim the tax treaty benefits in the case that the Russian legal entity (tax agent) pays dividends through a foreign depository bank, which further distributes them among GDR holders pro rated to their securities, the Russian tax agent should request informat…