OrbitaxParticipation exemption not applicable if decision to distribute dividends was made while Cyprus was on blacklist – Ministry of Finance clarifications
|Approved Changes|Russia
On 6 September 2013, the Ministry of Finance published Letter No. 03-03-06/2/9893, clarifying the applicability of the participation exemption to dividends distributed by a Cypriot subsidiary to its Russian parent company.
According to the Tax Code, to qualify for the participation exemption, the taxpayer has to meet the following requirements:
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