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Russia Clarifies Treaty Benefits for an Indirect Beneficial Owner of Dividends under Tax Treaty with Finland

|Treaty Development|Russia-Finland
Russia-Finland

Russia's Ministry of Finance has published guidance letter No. 03-08-05/86254 of 8 November 2019 and the application of the benefits of the 1996 tax treaty with Finland to dividends paid by a Russian entity through a Dutch intermediary. The letter clarifies that when an intermediary recognizes that it does not have an actual right to dividend income, the provisions of the tax treaty that Russia…