The Russian Ministry of Finance has published Letter No. 03-08-05/53455 of 12 August 2017, which clarifies whether dividends paid by a resident of the Vladivostok free port (0% corporate tax rate) to a resident of Australia are eligible for the reduced withholding tax rate (5%) provided under the 2000 Australia-Russia tax treaty. As part of the conditions for the 5% rate, the dividends must be paid out of profits that have borne the normal rate of tax, which for a Russian resident means profi…