The Russian Ministry of Finance (MinFin) approved the guidelines for the mutual agreement procedure (MAP) established by double tax treaties (DTT) (the “Guidelines”). The Guidelines set the general rules for competent Russian state authorities (i.e. MinFin) to examine disputable matters in international taxation. For example, the Guidelines cover situations in which actions taken by tax authorities from one country result or may possibly result in double taxation, or when a party may qualify as a tax resident in two countries at once.
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