In accordance with the decision of the Extraordinary General Meeting of Shareholders of IDGC of Centre, PJSC (hereinafter - the Company) dated 30.12.2019 (Minutes № 02/19 of 31.12.2019), the Company paid dividends on ordinary shares from the Company’s net profit based on the results of 9 months of 2019. According to the decision, the amount of dividends per 1 share was 0,0200649 RUB.
The values of indicators D1 and D2, determined in accordance with paragraph 5 of Article 275 of the Tax Code of the Russian Federation for calculating the amount of tax to be withheld from the income of the taxpayer - recipient of the above dividends, were:
According to the financial statements prepared in accordance with Russian Accounting Standards for 2019, the net profit of the Company amounted to 214 681 429,51 RUB. The size of the paid interim dividends for 9 months of 2019 was higher than the net profit earned by the Company for the end of 2019.
In this regard, you are kindly requested to take note of the information below.
On the basis of Articles 224 and 250 of the Tax Code of the Russian Federation, and also taking into account the position of the Ministry of Finance of Russia and the Federal Tax Service of Russia1, the difference obtained is recognized as the income of the shareholders of the Company, which cannot be considered dividends and must be re-qualified as property received free of charge in cash (hereinafter - the other income). The tax rates provided for in paragraph 1 of Article 284 of the Tax Code of the Russian Federation for legal entities, paragraph 1 of Article 224 of the Tax Code of the Russian Federation for individuals - residents of the Russian Federation, and clause 1 of paragraph 3 of Article 224 of the Tax Code of the Russian Federation for individuals being non-residents of the Russian Federation must be applied to this income.
1 Letters of the Ministry of Finance of Russia dated 24.12.2008 No. 03-03-06/1/721, dated 13.04.2016 No. 03-03-06/2/21011, the Federal Tax Service of Russia dated 19.03.2009 No. SHS-22-3/210@, Office of the Federal Tax Service for the city of Moscow dated 07.15.2009 No. 16-12/072669 @.