Recently, the Federal Tax Service published Letter No. 03-08-13/55719 issued by the Ministry of Finance on 18 December 2013 clarifying the tax treatment of dividends paid by a Russian company to its shareholder, tax resident in Sweden, based on the Russia-Sweden Income Tax Treaty (1993) (Treaty). The Ministry of Finance pointed out that pursuant to article 10 of the Treaty, dividends paid by a company resident in Russia to a resident of Sweden may be taxed in Sweden. However, such dividends may also be taxed in Russia, but the tax shall not exceed 5% of the gross amount of the...