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Tax-transparent
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Transparent for tax purposes - situations where, in accordance with the tax legislation of the Contracting State, income or a portion of income from education or structure is subject to taxation not at the level of the education or structure, but at the level of persons who have an interest in such education or structure, as if such income or portion of income were directly received by such persons at the time when such income or portion of income was actually received, regardless of whether such income or portion of income was distributed by these education or structure to such persons1.
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, art. 1. ↩
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