On February 18, 2026, at the BEPS Academy, Ravil Kassilgov and Rustam Vakhitov analyzed a recent court case on defending the actual right to income when paying dividends to the Netherlands.
How not to lose tax benefits when paying dividends abroad?
Court practice is changing the rules of the game. Tax authorities are demanding more and more evidence of actual income rights (AIR) and the existence of real “substance” from foreign companies.