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Qualified Person
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Qualified person - a resident of the Contracting State is considered a qualified person in the tax year only if such resident is: a) an individual; b) a relevant state organization; c) a company: i) whose main category of shares is listed on a recognized stock exchange... or ii) not less than 50% of whose shares... are directly or indirectly owned by five or fewer companies...; d) a charitable or other tax-exempt organization...; or e) a person who is not an individual... provided that..1.
Qualified person - a resident of the Contracting State is considered a qualified person at the time when the benefit would otherwise be granted under the provisions referred to in paragraph 1 of this article, if at that time the resident is: a) an individual; b) the Contracting State, any of its subdivisions or local authority, agency or state institution of the Contracting State, subdivision or local authority thereof; c) a company or other entity, if the principal class of shares is regularly traded on one or more recognized stock exchanges; d) a pension fund, if at the beginning of the tax year in which it claims the benefit, it holds at least 50 percent of its beneficial owners, members or participants are individuals who are residents of any Contracting State; or e) a person other than an individual, if during at least half the days in any twelve-month period that includes the time when the benefit would otherwise be granted, persons who are residents of this Contracting State and entitled to obtain the benefits specified in paragraph 1 of this article in accordance with sub-paragraphs "a", "b", "c" or "d" of this paragraph directly or indirectly own not less than 50 percent of the shares of this person2.
Agreement between the Government of the Russian Federation and the Government of the People's Republic of China on the Avoidance of Double Taxation and the Prevention of Tax Evasion with Respect to Income Taxes, as amended on 2016-05-23, Article 23. ↩
Convention between the Government of the Russian Federation and the Government of Japan on the Elimination of Double Taxation with Respect to Income Taxes and on the Prevention of Tax Avoidance and Evasion, as amended on 2018-11-12, Article 21. ↩
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