Russia's Ministry of Finance has published Letter no. 03-03-06/1/82163 of 25 October 2019, which clarifies eligibility for the dividend participation exemption following a merger.
The letter notes that Russia provides a general participation exemption for dividends where a participation of at least 50% in a distributing subsidiary is held for an uninterrupted period of at least 365 days on the date the decision to pay the dividends is made. The letter also notes that when one legal entity i…