Relief at source - eligibility, documentation, deadlines - Russian debt securities
Who can obtain relief at source?
Relief at source of withholding tax on dividends is available through Clearstream Banking for beneficial owners as follows:
|Eligible beneficial owners||Rate applicable at source|
Residents of Double Taxation Treaty (DTT) countries
Tax exempt entities recognised by Russian law
Russian legal entities
15%b from 1 January 2021
Non-resident legal entities
|15% / 20%c|
Non-resident legal entities with the dedicated article from Tax Code
a. According to the Russian Tax Code the Tax Identification number must be provided in case a Russian legal entity is eligible for exemption.
b. 13% until 31 December 2020.
c. Non-resident legal entities disclosing their legal status and residency are eligible for a reduced tax rate of 20% at source on interest from corporate bonds and 15% on mortgage-backed bonds.
Non-resident legal entities are furthermore eligible for 15% on interest from RUB-denominated corporate bonds issued in the period from 1 January 2017 to 31 December 2021, if providing the applicable NSD Tax codes.
d. Non-resident legal entities are eligible to 0% on Government bonds and Municipal bonds if providing the applicable article from the Tax Code justifying this exemption
All customers holding Russian corporate bonds or mortgage-backed bonds and applying for a reduced tax rate must submit:
- One-Time Certificate for Russian Bonds - before the first impacted interest payment; and
- Breakdown of Holdings - before each impacted interest payment as described in Forms descriptions - Relief at source and quick refund - Russian debt securities.
Deadlines for receipt of documents
The One-Time Certificate for relief at source of withholding tax on interest from Russian Government bonds, Municipal bonds, corporate bonds and mortgage-backed bonds must be received by Clearstream Banking at the latest on the record date, by 16:00 CET.
The Breakdown of Holdings must be received by Clearstream Banking at the latest on the record date by 16:00 CET.