Treaty between Russia and Sweden – Russian MoF clarifies required investment threshold with the view reduced withholding tax on dividends to apply

Recently, the Federal Tax Service published Letter No. 03-08-13/55719 issued by the Ministry of Finance on 18 December 2013 clarifying the tax treatment of dividends paid by a Russian company to its shareholder, tax resident in Sweden, based on the Russia-Sweden Income Tax Treaty (1993) (Treaty).
The Ministry of Finance pointed out that pursuant to article 10 of the Treaty, dividends paid by a company resident in Russia to a resident of Sweden may be taxed in Sweden. However, such dividends may …