Russia's Ministry of Finance has published guidance letter No. 03-08-05/86254 of 8 November 2019 and the application of the benefits of the 1996 tax treaty with Finland to dividends paid by a Russian entity through a Dutch intermediary. The letter clarifies that when an intermediary recognizes that it does not have an actual right to dividend income, the provisions of the tax treaty that Russia has entered into with the actual beneficial owner's country of residence may be applied, including a reduced withholding tax rate on dividends. Where the beneficial owner is resident in Finland, the 12% withholding tax rate...