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On 20 June 2016 the Commercial Court of Moscow rendered a decision in the case No. А40-51434/16-115-444 which is worth considering when assessing risks related to acquiring debt securities from foreign counterparties, and also to determine and confirm the status of beneficial owner of income for the purposes of applying international treaties for the avoidance of double taxation (“DTT”).
In this case a dispute was considered between Khanty-Mansi Bank Otkritiye PJSC the ("Bank") and Federal Tax Service Interregional Inspectorate No. 9 for Major Taxpayers. In the tax authority’s opinion, the Bank failed to withhold and pay profit tax at the rate of 20% when paying income upon acquisition of Eurobonds of Russian lenders on the secondary market from a Cyprus entity (the seller). The tax authority held that when paying the cost of the Eurobonds to a foreign entity that did not coduct acitivities through a permanent establishment in Russia the Bank also paid the amount of accrued interest (coupon yield) income (“accrued coupon yield”) taxable in Russia.
The Commercial Court of Moscow agreed with this position of the tax authority, being guided by the following arguments:
At the same time, the court rejected the Bank's arguments that:
As this case shows, the Commercial Court of Moscow has once again clarified the treatment of income paid when acquiring debt securities, both in the context of the provisions of the RF Tax Code, and in the context of interpreting the comments to Article 11 of the OECD Model Convention and the provisions of the particular DTT. This case supports the approach taken by the court in the Credit Europe Bank CJSC case (No. А40-442/15-З9-2) and develops the practice of interpreting the concept of the beneficial owner of income both in analyzing structures for issuing Eurobonds, and in the context of entitlement to a benefit under a DTT when disposing of securities.
Dentons’ lawyers are ready to provide comprehensive legal support in analyzing transactions for the sale of securities, assignment of debt obligations, asset ownership structures and financial flows as to whether those transactions and structures are subject to risks related to possible application of the beneficial owner concept, and other tools for combating tax evasion using international tax treaties, and in changing the forms of those structures to reduce any risks identified.
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