The Russian Ministry of Finance recently published Letter No. 03-08-05/24775 of 13 April 2018, which clarifies the application of Russia's participation exemption in relation to dividends paid to a foreign shareholder (Cyprus in this case) when the actual beneficial owner is a company resident in Russia. Under Russia's participation exemption, Russian residents are generally entitled to an exemption from tax on dividends received, provided that the resident has held, for an uninterrupted peri…