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Russia Publishes Guidance on Determination of Beneficial Ownership in Cases of Unlawful Application of Treaty Benefits

|Approved Changes|Russia
Russia

The Russian Federal Tax Service has published letter No. CA-4-7/9270, which sets out the approach for local tax authorities in court disputes involving contested findings that a tax agent unlawfully applied preferential tax treatment on income of a foreign entity under an international tax treaty.

In particular, the letter addresses the concept of beneficial ownership, and states that for the purpose of determining if a foreign entity is the beneficial owner of the income in question, the …

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