The Russian Ministry of Finance has published Letter No. 03-08-05/10372 of 19 February 2019 concerning the application of the reduced withholding tax rate provided under the 1993 tax treaty with Sweden. The letter notes that under the treaty, a 5% withholding tax rate applies on dividends where the beneficial owner owns 100% of the paying company's capital, or 30% ownership in the case of a joint venture, and the invested capital is not less than USD 100,000 or equivalent at the time of distribution. The letter provides that for Russia, the meaning of a joint venture is based on the...