On the basis based of Russia-United Kingdom Income Tax Treaty, the Ministry of Finance released Letter No. 03-04-05/24803 issued on May 23, 2014 regarding the tax treatment of interest paid by a Russian company to an individual resident in UK. According to the article 11 of the treaty, if the recipient is the interest’s beneficial owner then interest rises in Russia and paid to a UK resident have tax ability only in UK. Due to exemption in Russia, the article 232 of the Tax Code provides that the non-resident individual should provide to the income payer (i.e. the Russian company), a tax residence certificate and a foreign tax authority confirmation that income received will be subject to tax in UK. This confirmation may be submitted within 1 year after the end of the tax period when the income was obtained or before the interest payment.
Ireland and Denmark signed a Protocol
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