In accordance with the Russian Tax code and international Double Tax Treaty agreements (DTT) foreign investors whose assets are held on beneficial owners’ accounts should provide Certificate of Residence issued in 2015 in order to benefit from the tax exemption/tax reduction for the income derived from the sources in the Russian Federation.
The Certificate of Residence must be provided in original, be valid for the calendar year of the issue, as well as properly legalized and apostilled. Investors should also note that depending of the specific DTT conditions additional documents, such as Purchase and Sale agreements and other related documents, can be required for tax exemption/tax reduction and can also be requested by the Russian tax authorities for the purpose of verification of the correct tax calcualtion.
The provision of Certificates of residence for underlying clients of foreign nominee account holder which safekeep securities on foreign nominee accounts is not required for the purpose of tax collection. However, such documents can be required by the Russian tax authorities during the tax audit for verification of the correct tax calculation.
Impact on investors: Properly issued Certificate of Residence for 2015 should be provided by investors to AO UniCredit Bank for the purpose of DTT rules application.