Russia's Ministry of Finance has issued a guidance letter to clarify the reduced withholding tax rate on dividends provided under the 1996 tax treaty with Germany in cases where a Russian company invested in by a German shareholder has been involved in a reorganization. The letter notes that in order for the 5% withholding tax rate provided under the treaty to apply, the German beneficial owner must directly hold at least 10% of the paying company's capital and value of the holdings must be a…