A message to NSD’s clients regarding Russian Ministry of Finance’s Letter No. 03-08-05/3944 dated 2 February 2015 posted on NSD’s web site

05 February 2015
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Attn.: NSD’s Clients

NSD hereby informs its clients that:

1. A new letter issued by the Russian Ministry of Finance (Letter No. 03-08-05/3944 dated 2 February 2015) has been posted on NSD’s web site (in the ‘Tax Management’ section). According to the said Letter, where a securities depository acting as a withholding agent receives summarized information from a foreign nominee, according to which the actual recipient of income on bonds is a Russian organization, the securities depository shall not withhold tax. Russian organizations are, therefore, solely responsible for calculating and paying corporate income tax in accordance with Chapter 25 of the Russian Tax Code.

2. To comply with the provisions of the said Letter:

2.1. The Reference List of General Tax Rates under the Russian Tax Code, as posted on NSD’s web site (in the ‘Tax Management’ section, under ‘Russian Securities/Foreign Nominees’), has been replaced. The new Reference List contains a line providing for a zero tax rate for the purposes of tax exemption of Russian organizations disclosed by foreign nominees, with respect to interest income:

Налоговый кодекс
Tax code
Тип финансового инструмента
Type of financial instrument
Тип лица
Type of person
Налоговое резидентство
Tax residency
Ставка налога НК РФ
Tax rate under the Russian Tax code
Тип дохода
Type of income
Статья
Aarticle
Пункт
Point
Подпункт или абзац
Subsection or paragraph
1 2 3 4 5 6 7 8
246 1 2 Облигации/ Russian corporate bonds Российское юридическое лицо/ Russian Legal Entities Резидент/ Russian Tax Resident 0 Процентный доход/ interest income

2.2. The relevant amendments have been made to “NSD’s Terms and Conditions of applying tax rates in accordance with the provisions of the Russian Tax Code and double taxation treaties of the Russian Federation”:

TAX DISCLOSURE
of the foreign nominee

RATES TO BE USED BY THE WITHHOLDING AGENT (NSD)
(Tax Code of the Russian Federation in effect from 01/01/2015)

Tax jurisdiction disclosed
(should be disclosed in a column 2,3 in a block  Summarized
Tax Information of GF065)

Additional disclosure related to privileges 
(should be disclosed in a column 5,6,7 in a block  Summarized
Tax Information of GF065)

EQUITIES

BONDS

Note
Legal entities Individuals Legal entities Individuals
1 2 3 4 5 6 7
Tax resident of the Russian Federation (Russian organization) is disclosed a reference to the Russian Tax Code – article 246, clause 1, paragraph 2 (Russian corporate bonds) - - 0% - Documents confirming the Russian organization’s status

2.3. Tax Disclosure Example No. 3 for payment of income on bonds has been posted:

Summarized Tax Information:

Entry No. Tax Jurisdiction* Legal Entity / Individual (Article 310/214 of the Russian Tax Code) Reference to the Ground for Application of Tax Benefits (under the Russian Tax Code or International Treaties) Quantity of Securities Claimed Tax Rate
Code Name Article Number Clause of the Article Subclause/ Paragraph Additional feature
1 2 3 4 5 6 7 8 9 10
1 IT ITALY 310 11 2     1100 10
2 IT ITALY 310 284 2 1   1200 20
3 IT ITALY 214 11 2     100 10
4 IT ITALY 214 224 3 1   200 30
5 RU RUSSIAN FEDERATION 310 284 1     1500000 20
6 RU RUSSIAN FEDERATION 310 246 1 2   10600 0

* - hereinafter Tax Jurisdiction – country of the tax residents of the disclosed entities


Should you have any question related to this message, please do not hesitate to contact your account manager at (495) 956-27-90 or (495) 956-27-91.

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