The Russian Ministry of Finance recently published a guidance letter concerning confirmation of tax residence for the purpose of applying the beneficial withholding tax treatment for dividend payments under the 1994 tax treaty with the UK where multiple dividend payments are made during the year. In particular, the letter addresses a Russian dividend payer's question on whether a residence certificate is needed before each payment, considering that UK HMRC's standard practice is to indicate that a UK entity is tax resident on a specified date and that HMRC only issue certificates indicating residence for a period when in relation to...