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Treaty between Russia and Netherlands – clarifications on income obtained by Dutch parent company due to reduction of its shareholding in Russian subsidiary

25 December 2013

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Treaty Development

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Netherlands; Russia

The Ministry of Finance published Letter No. 03-08-05/43186, issued on 16 October 2013, clarifying the corporate income tax treatment of the income received by a Dutch parent company further to the reduction of the share capital of its Russian subsidiary. A Dutch company, the sole shareholder of a Russian company, decided to reduce the share capital of its subsidiary by decreasing the nominal share value. As a result of this decrease, the Dutch shareholder received income in the amount not exceeding its initial contribution to the share capital. The Ministry of Finance clarified that income received by a Dutch shareholder...