The Chimera of the Beneficial Ownership Rule in Russia
This article originally appeared in Bloomberg BNA. To read it in full, please see PDF link on the right.
Kirill Vikulov from Baker McKenzie explains that to apply tax treaty benefits, foreign companies must now provide beneficial ownership confirmations to Russian payers of income. Confirming beneficial ownership under Russian rules may go beyond the OECD test on proving legal ownership and having no connected obligation to pass on payments. What makes Russia’s beneficial ownership approach different based on recent vibrant court practice?