Russia Clarifies Application of Tax Treaty and Domestic Tax Law Provision on Dividend Income of Russian Parent from Kazakhstan

The Russian Ministry of Finance recently published a guidance letter concerning the application of the provisions of the 1996 Kazakhstan-Russia tax treaty and the Russian Tax Code on dividends paid by a Kazakhstan subsidiary to its Russian parent.

With respect to the tax treaty, the letter notes that the dividend payment may be subject to withholding tax at a rate of 10% in Kazakhstan as per the provisions of Article 10 (Dividends). With respect to the taxation of the dividend income in Rus…