Details of the official clarification by the Russian Ministry of Finance, dated 6 June 2008, regarding application of the lower withholding tax rates on dividends of the income and capital tax treaty between Russia and Cyprus, have become available.
Under Art. 10 of the treaty, the maximum withholding tax rate on dividends is 5% if the beneficial owner is a company that has directly invested in the capital of the company paying the dividends, an amount not less than the equiv…