The Federal Tax Service (FTS) has issued a letter no. SD-4-3/2765 on 19th February 2016 for clarifying the tax treatment of dividends received by a foreign company which voluntarily chooses to be considered as a Russian tax resident. According to article 246.2 (8) of the Tax Code, a foreign company carrying out its activities through a separate subdivision in Russia may voluntarily choose to be qualified as a Russian tax resident under certain conditions. FTS describes that in accordance with article 246 (5) of the Tax Code, a foreign company should be treated equally as a Russian company. So, dividends received by such foreign company should be taxed at the tax rates provided for Russian companies in sections 1 and 2 of article 284 (3) of the Tax Code. Again, on the basis of section 1 of article 284 (3) of the Tax Code, dividends received by resident companies from other resident companies are exempt from corporate income tax and withholding tax (participation exemption) if certain conditions are fulfilled. According to section 2 of article 271 (4) of the Tax Code, the received date of dividend income should be deemed to be the date when dividends are received in the bank account of the taxpayer.
Treaty between Botswana and Czech Republic negotiated
Related Posts

Russia proposes higher taxes on passive income, e-commerce, natural resource rents in 2027–2029 budget package
Russia’s Finance Ministry has proposed a series of Tax Code amendments as part of a budget package submitted to the
Read More
Russia proposes tax breaks for Unified Advanced Development Territory residents
Russia’s Ministry for the Development of the Russian Far East and Arctic has prepared amendments to the Tax Code,
Read More
Russia plans tax increases to fund military spending through 2029
The Russian government unveiled its draft three-year budget on 24 September 2026, laying out plans for 2027 through
Read More
Qatar, Russia sign MoU to strengthen technical cooperation in tax administration
The State of Qatar and the Russian Federation signed a memorandum of understanding (MoU) on technical cooperation in
Read More
Russia clarifies registration rules for subdivisions, foreign organisations
The Russian Federal Tax Service has issued clarifications on changes to the rules governing the registration of
Read More
Russia: Government extends export duty on oilseed flax until 2028
The Government of Russia has extended the export customs duty on oilseed flax leaving the country for destinations
Read More