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Russian Court Holds Gratuitous Financial Assistance Does Not Qualify as Participation for Reduced Dividend Withholding Rates Under Tax Treaties

|Treaty Development|Russia-Austria
Russia-Austria

An arbitration court in Russia recently issued a decision regarding whether gratuitous financial assistance provided by a non-resident shareholder in a Russian company may be considered in determining if a minimum participation condition is met for the purpose of a reduced withholding rate on dividends under a tax treaty. The case involved dividends paid by a Russian company to an Austrian shar…

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