Ivan Nasonov and Daria Konoplina of KPMG Russia evaluate the development of the look-through approach and explain how tax authorities are becoming increasingly committed to challenging the concept.
At the very end of 2018, Federal Law No. 424-FZ was passed, seeing several significant changes to Russian tax legislation regarding the beneficial ownership concept.
In April 2018 the Federal Tax Service of Russia issued a letter (Letter No. CA-4-9/8285@) containing guidelines for lower tax authorities on how to use the beneficial ownership concept when applying treaty benefits in Russia.
