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Application of the participation exemption in the case of restructuring of parent company through merger – Ministry of Finance clarifications

|Approved Changes|Russia
Russia

On 28 August 2013, the Ministry of Finance issued letter No. 03-03-06/2/35300 clarifying how to calculate the holding period of the shares with the view to apply the participation exemption of dividends in the case that the parent company merged with another company.

According to the Tax Code, to qualify for the participation exemption, the following requirements have to be met:

-   the parent company holds a minimum par…

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