Dividends Paid To Foreigners: Tax Issues

When paying out dividends, foreign organizations must calculate their income tax base. To avoid double taxation, the organization needs to determine its foreign stockholders’ share in its registered capital. This can be difficult to do if influxes of registered capital occurred at different times and in different currencies.

The simple solution for resolving is to calculate the foreign investor's share in the registered capital using the Central Bank's exchange rate listed for the date corresponding to each injection of capital. (Ministry of Finance Letter N 03-08-05 from September 10, 2009).