Russia's Ministry of Finance clarified in the Letter of 19 August 2011 (N 03-08-13) the conditions for application of the 5% withholding tax for purposes of article 10 of the treaty between Russia and Netherlands. According to article 10 of the treaty, dividend withholding tax is reduced to 5% if the beneficial owner of the dividends is a company which holds directly at least 25% of the capital of the company paying the dividends, and has invested in it at least 75,000 ECU or its equivalent in the national currencies of the contracting states. The amount of investment should be...