A protocol amending the DTT between Austria and Russia becomes effective as of 1 January 2020:
Dividends (Article 10)
5% of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividend
The full wording of the protocol is available in English under the following link:
Impact on investors: The provisions of the protocol will apply in Austria for all income received from 1 January 2020 onwards, however tax reclaims will be possible on 1 January 2021 at the earliest.