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THE SUPREME COURT EXPLAINED IN WHICH CASE IT IS IMPOSSIBLE TO APPLY A REDUCED TAX RATE FOR CROSS-BORDER PAYMENT

The highest authority noted that in cases where the counterparty organization in the country with which the agreement on avoidance of double taxation was signed is, in fact, an intermediary of an offshore company, the Russian taxpayer will not be able to apply a reduced rate. In case no. A40-121109/2022, the Supreme Court issued ruling no. 305-ES23-13710 clarifying the position of the highest instance on the above issue. In particular, it discusses the nuances of applying a reduced tax rate on...

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