On 8 October 2012, the Ministry of Finance issued letter No. 3-8-05 clarifying the conditions for application of the reduced withholding tax rate on the dividends paid by a Russian legal entity to the parent company resident in Finland in case of increase of the share capital. Under the Finland-Russia Income Tax Treaty (1996), the reduced withholding tax rate of 5% on dividends applies provided that the beneficial owner of such dividends is a company which owns directly at least 30% in the subsidiary and the foreign capital invested exceeds USD 100,000 or its equivalent in the national currencies of both...