The Russian Ministry of Finance recently issued Guidance Letter 03-08-05/37090, which clarifies eligibility for the withholding tax exemption for interest paid on bonds issued by a Russian corporate borrower under the laws of a foreign country. According to the letter, interest payments on such bonds to a foreign company are exempt from withholding tax provided the following conditions are met:
- The foreign company has the actual right to receive the income (proof of beneficial ownership may …