The Russian Ministry of Finance recently published a guidance letter concerning the application of the provisions of the 1996 Kazakhstan-Russia tax treaty and the Russian Tax Code on dividends paid by a Kazakhstan subsidiary to its Russian parent. With respect to the tax treaty, the letter notes that the dividend payment may be subject to withholding tax at a rate of 10% in Kazakhstan as per the provisions of Article 10 (Dividends). With respect to the taxation of the dividend income in Russia, the letter notes that dividend income received is included in taxable income and subject to the corporate...