Treaty between Russia and Venezuela – clarifications whether the National Treasury Office of Venezuela qualifies as a governmental body for tax treaty purposes

The Ministry of Finance issued Letter 03-08-05, clarifying the tax treatment applicable to interest paid by a Russian legal entity to the National Treasury Office of Venezuela based on the Russia - Venezuela Income and Capital Tax Treaty (2003) (the Treaty).

According to article 11 paragraph 2 of the Treaty, interest arising in Russia that is paid to a beneficial owner resident of Venezuela may be taxed in Russia, but the tax charged in Russia cannot exceed 5% if the interest …