The Ministry of Finance has issued Letter No. 03-03-РЗ-15941 on April 8, 2014 clarifying the application of the participation exemptions in the case where the subsidiary is subject matter to reorganization. Pursuant to general rule, for qualifying participation exemption, the parent company has to satisfy minimum 365 days holding period and not less than 50% shareholding in the company paying the dividends. Lastly, the Ministry of Finance clarified that for the objectives of application of the participation exemption, the holding period computes commences from the moment of the state registration of the new reorganized subsidiary.
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