Russia's Ministry of Finance recently issued Letter No. 03-00-RZ/16236, which clarifies the condition for beneficial ownership when claiming tax treaty benefits for passive income (dividends, interest, royalties). The letter states that in order to be considered a beneficial owner, the entity must not only be entitled to receive the passive income, but must be a direct beneficiary with the power to decide the further "economic fate" of the income.
The letter provides additional criteria for de…