Russia's Ministry of Finance recently published Letter No. 03-12-11/2/37057 of 31 May 2018 concerning the application of tax treaties when dividend or interest payments are made to a foreign organization that is not the actual beneficial owner of the income. The letter clarifies that in such case, the beneficial provisions of a tax treaty that Russia has with the jurisdiction in which the foreign organization is resident do not apply. However, if the payer of the income is aware of the actual…