OrbitaxTreaty between Russia and Cyprus – Russia clarifies "directly invested" for purposes of application of lower withholding tax rates on dividends
|Treaty Development|Russia; Cyprus
On 10 December 2009, the Ministry of Finance of the Russian Federation issued Letter No. ÌÍ-17-3/226 clarifying the application of the reduced withholding tax rate (5%) on dividends under the Russia-Cyprus tax treaty signed 5 December 1998.
According to the treaty, the 5% rate applies to the gross amount of the dividends if the beneficial owner has directly investe…
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