Notification to the shareholders on OJSC Enel Russia dividend payment
for 2014
For the purposes to comply with the standards of the Tax Code of the Russian Federation in part
of application of the tax rates for dividend payment to different categories of shareholders of OJSC Enel
Russia informs you as follows.
1. Confirmations to be provided by foreign legal entities and natural persons
1.1. Shareholders - legal entities not being residents of the Russian Federation seeking dividend
income taxation in accordance with provisions of international treaties pursuant to Article 312 of the Tax
Code of the Russian Federation shall provide the Issuer with confirmation of their domicile in the
country that has international treaty (agreement) regulating taxation issues with the Russian Federation.
The confirmation specified is deemed duly executed provided that all following conditions are complied
with:
• the confirmation includes the following wording or wording similar
by implication: "It is confirmed that the company ___________________ (company name)
________________ has been within ___________ (specify period)____________ an entity
with its domicile in ________________________ (specify country) _______________ as
defined in the Agreement (specify international treaty)
between the Russian Federation/USSR and _____________ (specify foreign
country)_______";
• confirmation is certified and apostilled by a competent authority of the foreign country, as
defined in the relevant agreement;
• confirmation is translated into Russian;
• confirmation is dated the year when the dividends are paid (2015).
Provision of the specified confirmation is allowed both in the form of original and notarized
copy.
1.2. Should the international treaties (agreements) between the Russian Federation and a foreign
country include provisions (limitation of benefits) limiting possible application of these treaties
(agreements) to income taxation of certain categories of persons, including to dividends, residents of the
said foreign countries in addition to the documents specified in clause 1.1 shall provide additional
confirmations. Confirmations shall include the information that the residents of the said countries are not
subject to limitations established by the relevant treaties (agreements). The specified confirmations can
be included in certificate of residency or in certain statements issued by competent authorities of relevant
foreign country. The specified confirmations shall be apostilled and translated into Russian.
In particular, to confirm possible application of benefits for the resident shareholders of the
United States the document confirming the domicile in the United States of America, or individual
statement, shall include the following wordings:
"[Shareholder name] meets the requirements specified in subclause [specify subclause] of clause
1, Article 20 of the Treaty between the Russian Federation and the USA dated 17.06.1992 On the
Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income
and Capital and has the right to tax exemption in accordance with the above mentioned treaty".
In confirmation of possible application of benefits for the resident shareholders of Great Britain
the documents confirming the domicile in Great Britain, or individual statement, shall include the
following wordings:
"[Shareholder name] is subject to taxation and shall not apply lower rates of income and capital
gains tax in accordance with the laws of Great Britain that provide for beneficial conditions for raising
foreign investments".
In confirmation of possible application of benefits for the resident shareholders of the Republic
of France, the documents confirming the domicile in France, or individual statement, shall include the
following wordings:
"[Shareholder name] for the purposes of provisions of Convention between the Government of
the Russian Federation and the Government of the Republic of France for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion and Fraud with Respect to Taxes on Income and on
Capital is subject to income tax in accordance with the common law provided for in the tax laws of
France and is exempt from this tax on the basis of these dividends".
1.3. Should the international treaties (agreements) include provisions establishing additional
conditions when complied with the lower tax rates may be applied to the dividend income, in particular,
when dependency of the tax rate on the amount of investments made is established, residents of foreign
countries seeking application of the specified lower rates to their dividend income, in addition and apart
from documents specified in clauses 1.1-1.2, shall submit the documents confirming their right to
taxation at lower rates (including certified copies of purchase and sale agreements for the whole
shareholding, payment documents for the whole shareholding, confirmations that shares are credited on
the shareholder's account).
1.4. Should natural persons, not being tax residents of the Russian Federation, seek dividend
income taxation in accordance with provisions of international treaties, the said persons shall submit the
documents confirming their domicile in the countries that signed international treaties regulating taxation
issues with the Russian Federation in accordance with the procedure established in Article 232 of the Tax
Code of the Russian Federation.
1.5 Pursuant to subclause 1, clause 4 of Article 7 of the Tax Code of the Russian Federation,
provisions of international treaties of the Russian Federation shall be applied with respect to the persons
who actually have the right to the income to be paid (their part) in accordance with the procedure
provided for in international treaty of the Russian Federation.
For the purposes of determining the actual dividend income recipient (beneficiary owner) and
applying lower rates established by international double taxation avoidance agreements, OJSC Enel
Russia, in addition to the documents mentioned above, has the right to request the following documents
(information):

documents (information) confirming (denying) that the income recipient has the power of
discretion in respect of the order and use of the dividends received;

documents (information) confirming that the income recipient with the place of
registration or domicile in the country (territory) that signed international double taxation
avoidance treaty with the Russian Federation, has liabilities subject to payment and their
occurrence confirm lack of saving on withholding tax in the Russian Federation with
further transfer of received monetary funds to third persons (for their domicile of place of
registration is the country (territory) the Russian Federation has no any international
double taxation avoidance treaty with);

documents (information) confirming that the income recipient, whose place of
registration or domicile is in the country (territory) the Russian Federation signed
international double taxation avoidance treaty with, does the actual business in the
country (territory).
The documents shall be submitted to OJSC Enel Russia at the address: 7 Pavlovskaya Str., bldg.
1, Moscow 115093 before June 29, 2015. The documents shall be accompanied with the information
about the contact persons of the shareholder who seeks dividend taxation at lower rates (Full name,
phones and email).
Should the documents, confirming the right to taxation of the shareholders' income at lower
rates, are not submitted within the term established, and/or the documents submitted are not
deemed sufficient for substantiating the right to dividend income taxation at lower rates, taxation
of the specified income will be done at the rates established by the laws of the Russian Federation.