| look-through approach | сквозной подход (The look-through approach (LTA) concept, which is used when claiming treaty benefits in Russia, has been actively applied by Russian tax authorities and taxpayers for several years. The LTA allows for the access of withholding tax (WHT) treatment in Russia under the double tax treaty (DTT) with a person, which is not an immediate recipient of a Russia-sourced income, but nonetheless is a beneficial owner of such an income.: Many Russian groups of companies use foreign holding companies to hold Russian assets for various reasons. But taking into account the limited functions of such holding companies and given the pressure from the harsh application of the Russian beneficial ownership rules, some Russian companies have switched to the so-called “look-through approach” ignoring intermediary holding companies for Russian tax purposes. The Russian “look-through approach” rules initially allowed Russian owners to apply the participation exemption as if the dividends had been distributed directly from the Russian subsidiary. • В частности, принципиальная возможность применения сквозного подхода была продекларирована в законодательстве только для дивидендных платежей.  globalcompliancenews.com 'More) |
