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 and protocols between Russia and Germany, 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 with a direct holding of at least 10% of the capital of the company paying the dividends, and th…