Article 10 of the double tax agreement between Cyprus and Russia provides that withholding tax payable on dividends paid by companies resident in one state to shareholders resident in the other is capped at 5% of the gross dividend, provided that the beneficial owner of the dividends is a resident of the other state and has directly invested the equivalent of at least €100,000 in the capital of the company paying the dividends.
Cyprus-Russia Double Tax Agreement – Importance of Proper Structuring
