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You hold the shares. The dividends never arrived. The deadline is approaching

Foreign investors who held shares in Rostelecom PJSC as at 1 December 2023 but did not receive the dividends declared for the full financial year 2022 may still be able to claim the amounts due to them.

This may apply to holders of:

• Rostelecom shares held through a non-Russian broker, bank or custodian;
• Russian shares received following the automatic, mandatory or standard conversion of Rostelecom American Depositary Receipts;
• shares transferred to a Russian custodian or the Russian shareholder register after ADR conversion;
• securities for which payment failed because of a break in the international custody chain, missing bank details or other infrastructure restrictions.

However, the period for claiming unclaimed dividends is about to expire.

The claim must be submitted no later than 19 November 2026.

To allow sufficient time to prepare the evidence, arrange the power of attorney, conduct the notarial inspection, legalise the documents and deliver the application in Russia, MAGENTA Legal accepts new instructions for this project until 15 September 2026.

After that date, we will consider new matters only on a case-by-case basis and only where sufficient time remains to prepare and file the documents properly.

Key information about Rostelecom’s FY2022 dividends

Item	Information
Issuer	Rostelecom PJSC
Ordinary shares	RTKM
Class A preferred shares	RTKMP
Dividend period	Full financial year 2022
Date of the General Meeting of Shareholders	20 November 2023
Dividend record date	1 December 2023
Dividend per ordinary share	RUB 5.4465
Dividend per Class A preferred share	RUB 5.4465
Claim deadline	19 November 2026
Deadline for instructing MAGENTA Legal	15 September 2026
Minimum holding accepted	150,000 shares — historically equivalent to 25,000 ADRs at a 1:6 ratio

Rostelecom’s shareholders approved the dividend on 20 November 2023. The amount is the same for ordinary shares and Class A preferred shares: RUB 5.4465 per share. The total declared dividend amounted to approximately RUB 19 billion. This information is available on Rostelecom’s official website.

How much may be claimed?

The indicative gross amount is calculated using a simple formula:

Number of shares × RUB 5.4465

Examples:

Number of shares	Gross dividend amount
150,000	RUB 816,975
300,000	RUB 1,633,950
500,000	RUB 2,723,250
1,000,000	RUB 5,446,500

These figures are before applicable taxes, bank charges and other expenses. The actual amount received will depend on the investor’s legal and tax status, the documents submitted and the payment procedure applied.

In some cases, an investor may attempt to rely on a Double Tax Treaty and the reduced dividend tax rate available under that treaty. This possibility must be assessed separately and will generally require a properly issued and legalised tax residency certificate.

The existence and current status of a treaty can be checked preliminarily using the MAGENTA Legal Double Tax Treaty table.

Historically, one Rostelecom ADR represented six ordinary shares. The 1:6 ratio is confirmed on Rostelecom’s official Depositary Receipts page.

Why might foreign holders have failed to receive the dividends?

Under normal circumstances, dividends pass from the Russian issuer through the registrar, Russian and foreign custodians, banks and brokers to the ultimate investor.

After 2022, many international custody chains ceased to operate in their previous form. As a result, payments may not have reached the ultimate holder even where the investor’s economic interest in the shares remained intact.

Common reasons include:

• the shares were held through a foreign nominee;
• the foreign broker or custodian did not disclose the ultimate holder;
• one or more participants in the custody chain stopped cooperating;
• the ADRs were converted after the dividend had been declared
• the issuer or Russian registrar did not have the investor’s current bank details;
• the investor did not have an appropriate bank account in Russia;
• the payment was subject to Russian counter-sanctions restrictions;
• a foreign intermediary did not provide a complete custody chain;
• relevant broker records were available only through an online account and could not be obtained as formally certified statements.

Failure to receive the payment in 2023 or 2024 does not necessarily mean that the right to the dividends has already been lost. The investor must, however, submit a claim and provide documentary evidence of entitlement.

Why should the claim not be delayed?

Under Article 42(9) of the Russian Federal Law on Joint-Stock Companies, a person who did not receive declared dividends because the company or its registrar lacked the necessary address details or bank details, or because of another form of creditor delay, may claim the unpaid dividends within three years from the date on which the dividend resolution was adopted.

A company’s charter may provide a longer claim period of up to five years. Rostelecom has not introduced such an extension: the company itself refers to the standard three-year period on its official dividend payment page.

This is not merely an ordinary limitation period. Russian law establishes a special statutory cut-off period. Once it expires, the unclaimed dividends are restored to the company’s retained earnings and the company’s obligation to pay them terminates.

As a general rule, a missed deadline cannot be reinstated. The relevant provisions are set out in Article 42(9) of the Federal Law on Joint-Stock Companies.

The claim for Rostelecom’s full-year 2022 dividends must be submitted no later than 19 November 2026.

Before filing, it is necessary to:

• identify the applicable procedure;
• verify the investor’s entitlement;
• reconstruct the custody chain;
• collect evidence of share ownership;
• execute and legalise the power of attorney;
• secure electronic evidence through a notarial inspection;
• obtain and apostille a tax residency certificate where appropriate;
• prepare the application;
• arrange translations and urgent delivery of the documents;
• allow time to address possible comments or additional requests.

For these reasons, our working deadline for accepting instructions is 15 September 2026.

Who may be eligible?

We primarily consider matters involving investors who were the owners or ultimate beneficial holders of the relevant Rostelecom shares as at the record date of 1 December 2023 but did not receive the dividends.

The procedure may be relevant in the following situations.

1. The shares were held through a foreign broker or bank

The shares may have been held through an international custody chain in which the ultimate investor was not identified directly in the Russian shareholder register.

In this situation, the evidence must establish the link between the Russian issuer, nominee holders, foreign custodian, broker and ultimate investor.

2. Rostelecom ADRs were converted into Russian shares

Where an investor received Russian shares following an automatic, mandatory or standard ADR conversion, dividends declared before completion of the conversion, or payments that failed to pass through the former custody chain, may not have been credited automatically.

Such payments may have to be claimed separately.

This project applies only where the ADRs have already been converted into Russian shares. If the Rostelecom ADRs were never converted, MAGENTA Legal does not currently accept instructions to recover the FY2022 dividends discussed in this publication.

3. The shares are now held in Russia, but the dividends are missing

The fact that the shares are currently held in a Russian securities account or shareholder register does not necessarily result in the automatic payment of previously declared dividends.

The investor must establish that they were entitled to the dividends on the relevant record date.

4. The investor subsequently sold or transferred the shares

Entitlement to a particular dividend is determined as at the record date established by the shareholder resolution.

A subsequent sale or transfer does not necessarily extinguish the investor’s right to a dividend declared for an earlier period. Ownership or beneficial entitlement as at 1 December 2023 must nevertheless be proved.

What documents are required?

The final document package is determined individually. It will generally include the following.

A notarised power of attorney for MAGENTA Legal representatives

We prepare the draft power of attorney, adapt it to Russian legal requirements and assist the client throughout the execution process.

If a notary in the client’s country refuses to notarise the document, does not understand the Russian procedure or requests changes to the wording, we consider alternative arrangements.

Depending on the circumstances, these may include:

• adapting the form of the power of attorney;
• execution before a Russian consular officer;
• execution in another available jurisdiction;
• another legally permissible method of appointing a representative.

We have also developed additional solutions for situations in which a standard notarised power of attorney cannot readily be obtained. These solutions form part of MAGENTA Legal’s practical know-how and are disclosed individually after the client contacts us and formally confirms the instruction.

A notarised copy of the passport

The passport copy must be properly notarised and will generally have to be apostilled or otherwise legalised as applicable.

It must then be translated into Russian in accordance with Russian formal requirements.

We provide instructions for the notary and assist with legalisation and translation.

A tax residency certificate – where a Double Tax Treaty is to be considered

If the investor wishes to attempt to apply a Double Tax Treaty, or DTT, and claim a reduced treaty rate of tax on the dividends, the document package must include evidence of tax residence.

As a general rule, the following will be required:

• a tax residency certificate issued by the competent tax authority of the relevant jurisdiction;
• the original certificate or a document in a form accepted by the Russian tax agent;
• an apostille or another applicable form of legalisation;
• a Russian translation;
• notarisation of the translation where required.

The certificate must confirm tax residence for the period relevant to the payment. The precise requirements will depend on the jurisdiction, the investor’s status, the form of the certificate and the requirements applied by the Russian tax agent.

Possession of a tax residency certificate does not in itself guarantee the application of treaty relief.

With effect from 8 August 2023, Russia suspended the operation of certain provisions of its DTTs with a number of jurisdictions included in the Russian list of “unfriendly” countries. In many cases, the suspended provisions include those governing the taxation of dividends.

Consequently, the domestic Russian tax rate may apply even where the investor provides a valid tax residency certificate.

The Russian Federal Tax Service has confirmed that, for payments made after 8 August 2023, the status of the particular treaty and its individual provisions must be considered. Its position is set out in Federal Tax Service Letter No. ШЮ-4-13/14936@ dated 29 November 2023.

For an initial review, investors may consult the MAGENTA Legal DTT table.

The rules governing proof of foreign tax residence for individuals are set out, in particular, in Article 232 of the Russian Tax Code. Special rules for foreign legal entities are contained in Article 312 of the Russian Tax Code.

Before the certificate is obtained, we assess:

• whether a DTT between Russia and the relevant jurisdiction is in force;
• whether its dividend provisions have been suspended;
• whether the investor may qualify for the treaty rate;
• which formal requirements apply to the certificate;
• whether an apostille or another form of legalisation is required;
• whether including the certificate in the package is likely to serve a practical purpose.

A notarial inspection report for the online brokerage account

Many foreign brokers and custodians do not issue documents in a format customarily accepted by a Russian issuer or registrar. The necessary information may nevertheless be available through the investor’s online account.

In these situations, we arrange a notarial inspection of the electronic evidence. Together with the client, we determine in advance which pages, sections, transactions and documents should be recorded.

The notarial report may include:

• the account holder’s details;
• the name of the broker or custodian;
• the number of ADRs or shares;
• the acquisition date;
• the holding as at the record date;
• transaction history;
• information concerning the ADR conversion;
• custody statements;
• available information concerning the custody chain;
• correspondence with the broker or custodian.

There is no reason to be apprehensive about this procedure. Each client receives our dedicated memorandum explaining:

• how the inspection is conducted from a technical perspective;
• which information must be shown to the notary;
• how to prepare the online account;
• which risks should be considered;
• how unnecessary disclosure can be minimised;
• how the procedure can be completed efficiently and conveniently.

We manage the entire process, from preparing the inspection script to reviewing the final notarial report.

Many of our clients have already completed this procedure. As at the publication date, no data leaks or other adverse issues have been recorded in connection with notarial inspections organised by us.

Documents confirming the custody chain

The custody chain is the sequence of institutions through which the rights to the shares were recorded from the Russian issuer to the ultimate investor.

It may include:

• the Russian registrar;
• a Russian custodian;
• a foreign nominee;
• an international central securities depository;
• a custodian bank;
• a broker;
• the ultimate holder.

It is not always possible to obtain a single document describing the complete chain. This does not necessarily mean that the matter cannot proceed.

If the broker or custodian refuses to provide a custody chain, we review alternative evidence, combine information from several documents and record the missing information through the notarial inspection where appropriate.

We have developed a separate working methodology for these situations.

The application for payment of unclaimed dividends

MAGENTA Legal prepares the application in full.

The client does not need to determine its structure, draft the legal grounds or calculate the claim independently.

Where necessary, we also prepare explanations, covering letters, responses to additional requests and other documents required during the review process.

Urgent international document logistics

Powers of attorney, passport documents, tax residency certificates and other originals may have to be delivered to Russia within a very short period.

Ordinary international courier services do not always provide a sufficiently predictable solution, particularly as the filing deadline approaches.

MAGENTA Legal can arrange urgent personal collection and delivery of documents.

For example, in 2026 we arranged for our representative to collect a power of attorney personally in Hong Kong. The documents executed under that power of attorney were filed at the Moscow office within three days.

The availability of a similar arrangement will depend on the client’s location, visa and transport conditions, the readiness of the documents and the time remaining before the deadline.

What does MAGENTA Legal do?

We provide end-to-end support:

1. Conduct a preliminary assessment of the matter.
2. Verify the number and class of shares.
3. Review the ADR status and conversion procedure.
4. Establish the custody chain as at 1 December 2023.
5. Prepare an individual document checklist.
6. Draft the power of attorney and provide instructions for the notary.
7. Arrange legalisation, apostilles and Russian translations.
8. Assess the potential application of a DTT and the requirements for the tax residency certificate.
9. Prepare the notarial inspection of the online account.
10. Assist in establishing the custody chain or compiling an alternative evidentiary package.
11. Prepare and file the dividend claim in full.
12. Communicate with Rostelecom PJSC and JSC VTB Registrar.
13. Respond to additional requests and address comments.
14. Arrange urgent international delivery of original documents.
15. Where appropriate and subject to a separate agreement, assist with opening a bank account in Russia.

MAGENTA Legal has established effective working communication with Rostelecom and JSC VTB Registrar. This allows us to manage communications concerning applications and related enquiries professionally. It does not, of course, guarantee approval of a claim or payment of the dividends.

The client does not need to navigate the issuer’s requirements, Russian notarial formalities, the tax treatment of the payment or the complexities of the custody infrastructure independently. We prepare a step-by-step plan and assist throughout its implementation.

Where will the dividends be paid?

The payment route depends primarily on the investor’s status under Russian law.

Investors associated with “unfriendly” states

If an investor is classified as a person associated with a jurisdiction included in the Russian list of “unfriendly” countries, the payment will generally be made to a special Type C rouble bank account.

Under the applicable procedure, the Russian debtor arranges for the account to be opened in the foreign recipient’s name. The investor will generally not need to open an ordinary Russian bank account separately for this payment.

The funds in a Type C account belong to the investor, but their use is subject to substantial restrictions. For practical purposes, such dividends should currently be treated as frozen unless the regulatory framework changes or a specific permission is obtained.

A frozen payment and a lost claim are not the same thing.

If the investor files the claim in time and the dividends are credited to a Type C account, the amount due will be preserved for that investor. If the three-year claim period expires, the company’s obligation to pay the unclaimed dividends may terminate altogether.

Investors associated with “friendly” states

An investor who is not subject to the Type C account regime will generally require an active bank account in Russia to receive the dividends.

Where necessary, MAGENTA Legal can assist with opening such an account. Opening the account constitutes a separate instruction or an additional part of the project. Availability, scope, timing and fees are discussed individually with the client.

Where the investor:

• holds citizenship only of a “friendly” state;
• does not hold citizenship of any jurisdiction included in the Russian list of “unfriendly” countries; and
• is not subject to restrictions on any other grounds,

the dividends are unlikely to be frozen in a Type C account.

A final assessment can be made only after reviewing all citizenships and passports, the investor’s status, the ownership structure and the basis on which the shares were acquired.

What if the investor has several citizenships or passports?

As a general rule, a Russian citizen is treated in Russia primarily as a Russian citizen, irrespective of any additional citizenships or foreign passports. At present, the Type C account restrictions will generally not apply to Russian citizens in the circumstances discussed in this publication.

In certain cases, a Russian residence permit may also affect the investor’s classification and help avoid the restrictive regime. Obtaining a Russian residence permit may, however, involve significant practical difficulties.

For a foreign citizen, the decisive factor is not merely the possession of a passport issued by a “friendly” state, but the absence of citizenship of an “unfriendly” state.

In other words, if a foreign individual simultaneously holds:

• citizenship of a “friendly” state; and
• citizenship of an “unfriendly” state,

the “friendly” passport will not generally eliminate the risk of the Type C account regime. A possible exception requires individual assessment, particularly where the person is also a Russian citizen.

A developing practice is for foreign investors to be asked to provide additional evidence that they do not hold a second or other citizenship.

This may include a declaration of no other citizenship, notarised and, where required, apostilled or otherwise legalised.

Before accepting the matter, we therefore review:

• all current citizenships;
• current and previously issued passports;
• any Russian citizenship;
• any Russian residence permit;
• tax residence;
• place of permanent residence;
• the circumstances in which the securities were acquired and converted.

Minimum holding

MAGENTA Legal accepts instructions concerning Rostelecom’s full-year 2022 dividends where the client holds or held at least 150,000 Russian shares relevant to the claim.

If the shares were obtained through ADR conversion, the corresponding depositary receipts must already have been converted into Russian shares. Historically, 150,000 shares correspond to 25,000 ADRs at a ratio of one ADR to six ordinary shares.

If the ADRs were not converted into Russian shares, we do not currently accept instructions concerning the dividend payment discussed in this publication.

This publication relates exclusively to the dividend for the full financial year 2022 with a record date of 1 December 2023.

Why must MAGENTA Legal be instructed by 15 September 2026?

A cross-border claim cannot be prepared reliably within a few days.

Time will generally be required to:

• obtain documents from the foreign broker;
• reconstruct the custody chain;
• agree the wording of the power of attorney;
• attend a foreign notary;
• obtain an apostille or complete another legalisation procedure;
• obtain and legalise a tax residency certificate;
• deliver original documents internationally;
• arrange notarised Russian translations;
• conduct the notarial inspection;
• review and reconcile electronic evidence;
• prepare the application;
• address possible comments or requests for additional documents.

Accordingly, 15 September 2026 is not a statutory deadline. It is MAGENTA Legal’s internal deadline for accepting new instructions.

The purpose of this internal deadline is to preserve a realistic opportunity to prepare a proper document package and submit it in time.

We do not recommend relying on the final day of the statutory period. A formal right to claim will be of little assistance if the power of attorney, apostille or key evidence does not reach Russia before the deadline.

Frequently Asked Questions

Is it still possible to claim Rostelecom’s FY2022 dividends?

Potentially, yes.

If the investor was entitled to the dividend as at 1 December 2023 but did not receive it because of missing bank details, the foreign custody chain, ADR conversion or another form of creditor delay, the investor may submit a claim for payment of the unclaimed dividends.

The prospects will depend on the evidence available and the circumstances of the particular matter.

What was the exact dividend per share?

The dividend was RUB 5.4465 per share.

The same amount applies to ordinary shares, ticker RTKM, and Class A preferred shares, ticker RTKMP.

What was the dividend record date?

The persons entitled to the FY2022 dividends were determined as at 1 December 2023.

The investor must establish entitlement to the shares on that date.

When does the claim period expire?

The claim for unclaimed dividends must be submitted no later than 19 November 2026.

MAGENTA Legal’s internal deadline for accepting new instructions is 15 September 2026.

Can Rostelecom’s charter provide a longer claim period?

Russian law permits a company’s charter to establish a longer period for claiming unclaimed dividends, up to a maximum of five years from the dividend resolution.

Rostelecom has not adopted an extended period. The standard three-year period applies.

Can a missed deadline be reinstated?

As a general rule, no.

Russian law provides a very narrow exception where the person entitled to the dividends failed to submit the claim because of violence or threats.

Lack of awareness, difficulties with a broker, sanctions, missing documents or delays in executing a power of attorney do not generally allow the deadline to be reinstated.

What happens to the dividends after the deadline?

Declared but unclaimed dividends are restored to the company’s retained earnings, and the company’s obligation to pay them terminates.

This is why the claim must be prepared before the three-year period expires.

Can a Double Tax Treaty be applied?

In some cases, yes.

The investor will generally need a tax residency certificate issued by the competent authority of the relevant jurisdiction, apostilled or otherwise legalised as applicable and translated into Russian.

The certificate alone does not guarantee a reduced tax rate. It is also necessary to determine:

• whether the treaty between Russia and the relevant jurisdiction remains in force;
• whether its dividend provisions have been suspended;
• whether the investor satisfies the conditions for treaty relief;
• whether the Russian tax agent accepts the certificate in the form provided;
• whether the investor’s beneficial entitlement to the income has been established.

Since 8 August 2023, certain provisions of many DTTs with “unfriendly” states have been suspended. In those cases, tax may be withheld at the rate prescribed by Russian domestic law despite the tax residency certificate.

The existence and status of the relevant treaty can be reviewed preliminarily using the MAGENTA Legal DTT table.

Can a claim be submitted if the ADRs were never converted?

Not under the project described in this publication.

MAGENTA Legal currently accepts instructions only in relation to Russian Rostelecom shares, including shares received following ADR conversion.

If the depositary receipts were never converted into Russian shares, we do not accept instructions concerning the FY2022 dividend discussed here.

Is an ordinary screenshot of the brokerage account sufficient?

An investor-generated screenshot will often be insufficient.

Electronic information should preferably be secured through a notarial inspection. This makes it possible to record the contents of the online account, confirm its connection to the investor and document the number of securities and transaction history displayed.

Is the notarial inspection of the online account safe?

The inspection follows a prepared script.

We provide the client with a dedicated memorandum, explain the technical process and help limit the inspection to the information that is genuinely required.

As at the publication date, clients who completed inspections organised by us have not experienced data leaks or other adverse issues arising from the procedure.

What if the broker refuses to provide the custody chain?

A refusal by the broker does not necessarily make the claim impossible.

We review custody statements, transaction reports, trade confirmations, corporate action notices, conversion records and information available through the online account.

We then build a coherent evidentiary package from the available materials and, where appropriate, secure it through a notarial inspection.

Must the investor travel to Russia?

In most cases, the matter can be handled through a representative acting under a power of attorney.

The need for a personal visit is assessed separately, particularly where a Russian bank account must be opened or notarisation cannot be completed in the client’s jurisdiction.

What if the local notary refuses to notarise the power of attorney?

We provide instructions and consider alternative legally permissible methods of appointing a representative.

Some of the solutions used by us form part of MAGENTA Legal’s practical know-how and are disclosed after the client formally confirms the instruction.

The issue should be identified at an early stage rather than a few days before the filing deadline.

How quickly can the power of attorney be delivered to Russia?

Timing will depend on the client’s location and the delivery arrangement selected.

Where necessary, we may arrange personal collection and urgent delivery. In one 2026 matter, our representative collected a power of attorney personally in Hong Kong, after which the documents were filed in Moscow within three days.

Is a Russian bank account required?

An investor from a “friendly” jurisdiction who is not subject to the restrictive regime will generally need a Russian bank account.

Opening the account is a separate instruction or an additional part of the project and is discussed individually with the client.

For an investor subject to the Type C account regime, the special account will generally be opened as part of the payment process.

Can funds be withdrawn from a Type C account?

The use of funds held in a Type C account is substantially restricted.

Certain transactions may be permitted under Russian law, while others may require a specific authorisation.

Receipt of the dividends into a Type C account does not mean that they will immediately be available for transfer outside Russia.

Is there any point in claiming if the funds will be frozen?

Potentially, yes.

A timely claim may preserve the amount due to the investor. If no action is taken and the three-year period expires, the investor risks permanently losing the claim against the issuer.

The decision should take into account the size of the holding, the expected payment, the costs involved and the investor’s individual regulatory status.

What if the investor holds several citizenships?

The first issues to be examined are whether the investor is a Russian citizen and whether the investor holds citizenship of a jurisdiction included in the Russian list of “unfriendly” countries.

As a general rule, a Russian citizen is treated in Russia as a Russian citizen irrespective of any additional passports.

For a foreign investor, possession of a “friendly” passport may not resolve the issue if the person simultaneously holds citizenship of an “unfriendly” state.

In certain cases, a notarised and apostilled declaration confirming the absence of any other citizenship may be required.

Can the dividends be claimed if the shares have already been sold?

In some cases, yes.

Entitlement is determined as at the dividend record date. If the investor held the shares on 1 December 2023, a subsequent sale does not necessarily extinguish the right to the previously declared dividend.

The holding as at the record date must be proved.

Does filing an application guarantee payment?

No.

The outcome depends on the documents, the custody chain, the position taken by the issuer and registrar, the investor’s status, the applicable tax treatment and the regulatory framework in force.

Before accepting an instruction, MAGENTA Legal conducts a preliminary assessment and informs the client of the identified risks.

We do not guarantee the result, but we organise the procedure and prepare the evidentiary and legal position on the basis of the available documents.

How to start

For a preliminary assessment, please provide:

• the number of ordinary and preferred shares;
• the original number of ADRs, where applicable;
• confirmation of whether the ADRs were fully converted into Russian shares;
• the name of the foreign broker, bank or custodian;
• the date and method of ADR conversion;
• the current place of custody or registration of the shares;
• all citizenships and passports held;
• details of any Russian citizenship or Russian residence permit;
• the country of residence;
• the country of tax residence;
• whether an apostilled tax residency certificate can be obtained;
• whether any Rostelecom dividends were received after the conversion;
• details of the custody statements and other documents already available.

At the initial stage, the investor does not need to prepare the application, execute the power of attorney, obtain an apostille or order a tax residency certificate independently.

We first assess the ownership structure and the investor’s legal and tax status and then determine the required document package.

Instructions must be provided to MAGENTA Legal no later than 15 September 2026.

For operational updates, follow our new Telegram Channel dedicated to forced conversions.

If you have individual questions or require legal support, our Telegram Bot is available for direct assistance.

You can also reach our team via the contact form on our Website.

 

The information in this publication is current as at 28 July 2026 and is provided for general information only. It does not constitute legal, tax or financial advice or a guarantee that a Double Tax Treaty will apply, that an application will be accepted or that any dividend will be paid. The applicable regulations and practical requirements may change. Each matter requires an individual assessment.