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

... from this company. At the same time, XANGBO itself performed exclusively agency functions and did not reflect interest in its tax returns. Accordingly, the Singapore organization was not the actual recipient of income, since its powers in terms of income disposal were limited, and the company performed intermediary functions in the interests of a third party. The Supreme Court also noted that the Russian credit institution submitted to the Federal Tax Service an agreement on the provision of consulting services, which was signed by XANGBO and MTS, as well as acts ...

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