The Russian Ministry of Finance recently published Letter No. 03-03-06/1/8891, which clarifies whether a foreign legal entity treated as tax resident in Russia can qualify for the participation exemption on dividends. The exemption is provided under Article 284 section 3 of the Tax Code, which in general grants an exemption for dividends received by a Russian company if the company has held at least 50% of the paying company's capital for an uninterrupted period of at least 365 days. For tax …