English to Russian Other Law: Contract(s)

Dividends received by a fund resident in Cyprus from a foreign company are exempt from tax if either of the following conditions is satisfied:
(a) the dividend paying company derives 50% or more of its income directly or indirectly from activities which lead to active trading income (“active versus passive test"); or
(b) the foreign tax burden on the profits to be distributed as a dividend is not substantially lower than the Cypriot corporate income tax rate (i.e. a rate of at least 5% at the level of the dividend paying company) (“effective tax test").