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Treaty between Russia and Austria – Russian MoF clarifies tax treatment of dividends

27 June 2013

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Treaty Development

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Russia; Austria

Recently, the Ministry of Finance made available Letter No. 03-08-13/11441 issued on 8 April 2013, clarifying the tax treatment applicable to dividends under the Austria-Russia Income and Capital Tax Treaty (2000). The Ministry of Finance was asked whether the reduced withholding tax of 5% could be applied in case of dividends paid by a Russian company to its Austrian shareholder provided the latter acquired the shares in the Russian company for a cost exceeding the value of USD 100,000. Pursuant to article 10 of the tax treaty, dividends paid by a company resident in Russia to a resident of Austria...