Russia Clarifies Taxation of Dividends Received by Foreign Companies that have Elected to be Treated as a Resident Company

The Russian Federal Tax Service recently issued guidance clarifying the taxation of dividends received by a foreign company that is considered a Russian tax resident. A foreign company may be considered a Russian tax resident in a few different cases, but the guidance specifically refers to cases where a foreign company is domiciled in a country with which Russia has an effective tax treaty, the company carries on activities in Russia through a branch or other subdivision, and it has elected …