The Russia Ministry of Finance (MoF) recently issued Guidance Letter 03-08-05/17565, which clarified the tax treatment of income received by a Swiss resident from a Russian real estate investment fund, and the eligibility for a reduced withholding tax rate as provided for in the Russia-Swiss tax treaty.
Under the Russia-Swiss tax treaty, income from real estate investment funds are considered dividends. The withholding rates on dividends are 5% if the beneficial owner holds 20% or more of th…