The Russian Ministry of Finance has published Letter No. 03-06/1/95903 concerning whether income received from the sale of depositary receipts issued by foreign entities may qualify for the 0% income tax rate provided income from the sale or other disposal of shares (stakes) held for a continuous period of at least five years. The letter confirms that as per paragraph 4.1 of Article 284 of the Russian Tax Code, the 0% tax rate is only available in respect of shares (stakes) held in Russian en…