The Russian Ministry of Finance recently published Letter No. 03-08-05/1593, which clarifies the taxation of capital gains from the alienation by a Cyprus organization of shares in a Russian organization deriving more than 50% of their value from immovable property situated in Russia. According to the letter, under the 1998 Cyprus-Russia income tax treaty as amended by the 2010 protocol, the alienation of such shares deriving value from immovable property in Russia are taxable in Russia from 1 January 2017. It is uncertain what Cyprus' position is on the taxation of capital gains deriving value from immovable property since at...