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The RF North-West District Arbitrazh court gave broad interpretation to provisions on ultimate recipient of tax benefit by applying them to corporate restructuring.
DATE: March 29, 2016 | AUTHOR: atlawyers
The RF North-West District Arbitrazh court gave broad interpretation to provisions on ultimate recipient of tax benefit by applying them to corporate restructuring. The court held that in a popular restructuring scheme (contribution of shares in a Russian company to a Cyprus company, which, in turn, were put under control of a company in another jurisdiction (e.g. BVI), the ‘ultimate recipient of tax benefit’ was the end holding company, and not a Cyprus sub-holding.