The Russian Ministry of Finance recently published guidance letter No. 03-03-06/1/17848 of 2 March 2023, which clarifies the application of the participation exemption for dividends received. Russia's participation exemption (0% rate) for dividends is generally available for resident entities that have owned at least 50% of the paying company's capital for a continuous period of at least 365 days.
The letter clarifies that the exemption is also available when the company paying the dividends…