Letter No. 03-08-РЗ/10213 published by the Russian Finance Ministry explains the position with respect to dividends paid by Russian companies to Italian parent companies. The participation exemption is available if the parent company meets a 365 day holding requirement and if it has a 50% shareholding in the company that is paying the dividend. The participation exemption does not however apply when a Russian company pays a dividend to a foreign shareholder, but only when the dividend is paid to a Russian parent company.
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Saudi Arabia and Hungary sign a DTA
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