Russia's Ministry of Finance recently published Guidance Letter No. 03-08-05/46320, which clarifies the application of treaty benefits for dividends paid through a foreign intermediary. According to the letter, in order for the beneficial provisions of a treaty to apply, a non-resident must provide the Russian tax agent (dividend payer) a certified confirmation of permanent residence in the relevant treaty partner jurisdiction. If the non-resident direct participant (intermediary) in the Russ…