Dear shareholders,
In accordance with the procedure for payment and taxation of dividends established by the legislation of the Russian Federation, dividends on shares of RusHydro for 2021 will be paid within the following terms:
1. The term for payment of dividends to the nominee holder and a trustee who is a securities market professional registered in the shareholder register shall be no more than 10 business days (until July 22, 2022) from the date on which the persons entitled to dividends are determined.
The depository or a trustee responsible for the trust management of property on which dividends are paid shall be the tax agent in respect of income earned by shareholders (individuals, legal entities) whose right to securities is recorded in the depository.
2. The term for payment of dividends to the persons registered in the shareholder register and not specified in Clause 1 hereof shall be no more than 25 business days (until August 12, 2022) from the date on which the persons entitled to dividends are determined.
RusHydro shall be the tax agent in respect of income earned by shareholders (individuals, legal entities) whose right to securities is recorded in the shareholder register.
The shareholders specified in Clause 1 and entitled to a preferential tax rate shall submit documents confirming such right to the place where their right to RusHydro shares is recorded (the place where the shares they own are kept).
The shareholders specified in Clause 2 and entitled to a preferential tax rate shall submit the below documents to RusHydro no later than July 15, 2022 to the following address: 7 Malaya Dmitrovka St., Moscow, 127006.
If these documents are not submitted to the tax agent in a timely manner, then the latter shall have no grounds to apply the preferential tax conditions to income in the form of dividends. In such case, taxation will occur in accordance with the standard procedure established by law.
1. For shareholders – legal entities who are residents of the Russian Federation
The trustees of mutual funds must submit the following documents to the tax agent:
Trustees administering the funds in the form of amounts of income from investing pension savings formed in accordance with the legislation of the Russian Federation, received by organizations acting as insurers for compulsory pension insurance (subclause 31, clause 1 of Article 251 of the Tax Code of the Russian Federation (hereinafter, TC RF)) provide the following documents to the tax agent:
2. For shareholders – legal entities who are non-residents of the Russian Federation.
In order to apply the provisions of international agreements of the Russian Federation, foreign entities that are not tax residents of the Russian Federation must submit the following documents to the tax agent:
In addition, some international contracts stipulate application of a reduced tax rate with ownership of a certain number of shares of the company paying the dividends. In this case, the number of shares can be determined as a percentage of the authorized capital and in the amount for which the shares were purchased.
In such situations, in order to confirm the right to apply the appropriate reduced tax rates, the following documents are required in addition to the above confirmations:
To apply reduced rates under international contracts (agreements), it is necessary to additionally take into account the MLI provisions.
The MLI provides that provision of advantages by bilateral international contracts (agreements) will not apply if the main purpose (or one of the main ones) of the transaction is obtaining an advantage under bilateral international contracts (agreements).
The MLI provisions shall apply taking into account the ratified and effective position of the two countries.
The optional MLI provisions ratified by the Russian Federation, in particular:
They apply if the second party to an international contract (agreement) has also ratified these provisions and extended their effect to the agreement with the Russian Federation.
Registration and publication of the MLI final provisions, ratified by each of the jurisdictions, shall be made by the Organization for Economic Cooperation and Development (OECD) as Depositary of the Instrument.
The MLI has applied since January 1, 2021 with regards to the bilateral international contracts (agreements) of partner states to which the Russian Federation has sent a notification on completion of domestic procedures.