Russia's Ministry of Finance recently published a guidance letter clarifying the minimum investment conditions for the reduced dividends withholding tax rate under the 1996 income and capital tax treaty as amended by the 2007 protocol. Under the treaty as amended, a reduced withholding tax rate of 5% applies for dividends if the beneficial owner holds at least 10% of the basic or common stock of the company paying the dividends and such capital share amounts to at least EUR 80,000 or the equi…