The Russian Ministry of Finance recently issued Guidance Letter 03-08-05/48127, which clarifies the process for obtaining a refund of excess corporate tax withheld in cases where applicable treaty benefits were not applied at the time of payment.
According to the letter, a request for a refund must be made with the Russian tax authority with which the withholding tax agent is registered, and must be made within three years from the end of the tax period in which the payment to the non-reside…