The Russian Ministry of Finance further clarifies what is needed for confirming beneficial ownership for Russian source income.
In a recent letter issued by the Russian Ministry of Finance, they explained that, in order to apply reduced withholding tax rates under a double tax treaty, the recipient of the income must provide the tax agent with a tax residency certificate. In the same letter the Ministry states that the tax agent may also request confirmation that the recipient has the actual right to receive the corresponding income, i.e. that he is the beneficial owner of such income.
The latest comments could be interpreted that, in order to apply the reduced tax rates provided in the relevant treaty, both documents must be obtained before the date the income is actually paid.