On 3 June 2013, the Ministry of Finance issued Letter No. 03-03-06/1/20160 clarifying the tax treatment of dividends paid by a Russian company to its sole shareholder tax resident in Sweden, based on the Russia - Sweden Income Tax Treaty (1993).
The Ministry of Finance was asked whether the reduced withholding tax of 5%, provided by the tax treaty, could be applied in the case of dividends paid by a Russian company to its Swedish sole shareholder.
The Ministry of Finance pointed out …