The Russian Arbitration Court for Moscow recently issued its decision on the availability of treaty benefits for interest paid by a Russian legal entity to a Luxembourg entity acting as a financing intermediary. The case involved interest paid by Russian Bank Intesa to Intesa Sanpaolo Holding International in Luxembourg (IS Lux) on loans that were financed by Intesa Sanpaolo Milan Spa in Italy (IS Italy), which is a controlling shareholder of both the Russian and Luxembourg entities. For the period 2010 through 2011, Bank Intesa withheld no tax on the interest payments to IS Lux based on the exemption provided...