Russia's Ministry of Finance clarified in the Letter of 19 August 2011 (N 03-08-13) the conditions for application of the 5% withholding tax for purposes of article 10 of the treaty between Russia and Netherlands.
According to article 10 of the treaty, dividend withholding tax is reduced to 5% if the beneficial owner of the dividends is a company which holds directly at least 25% of the capital of the company paying the dividends, and has invested in it at lea…