Recently, the Russian Ministry of Finance (MoF) published Letter No. 03-08-05/49380 issued on 18 November 2013 clarifying the tax treatment applicable to interest paid by a Russian company to the Dutch branch of a Taiwanese bank. The Ministry of Finance referred to article 1 and article 3 of the Netherlands-Russia Income and Capital Tax Treaty (1996) (the Treaty), which provide that persons that are considered tax resident of one or both of the contracting states, including individuals, companies and any other body of persons, may claim the Treaty benefits. Therefore, the Ministry of Finance pointed out that in the case...