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The new profits tax law which came into force in 2002 significantly
changed the withholding tax regime applying to Russian
source income paid to foreign companies without a
permanent establishment in Russia. The new withholding
tax regime is now much closer to OECD principles and
the previously extremely bureaucratic procedure for
obtaining advance treaty clearances has been much
simplified.
Tax treaties to which the former USSR was party are honored by Russia,
unless the other party to the treaty has renounced
it or it has been replaced by a new treaty. In the
last few years Russia has entered into many new treaties
based on the OECD Model Convention.
A foreign company claiming an exemption from Russian withholding
tax based on a treaty must obtain and provide to the
Russian payor a confirmation from the foreign tax
authority that the company is tax resident in the
relevant treaty country. The tax authorities have
clarified the information, which is necessary to confirm
the eligibility of the foreign company to the treaty
exemption in such a certificate.
Table Of Treaty Rates
These rates
apply to withholding taxes on Russian source income.
Numbers in parentheses refer to notes below the table.
Country
Dividends
Interest
Royalties
Year Of Application
Albania
10
10
10
1998
Algeria
5/15
0/15
15
2009
Armenia
5/10
0
0
1999
Austria
5/15 (1)
0
0
2003
Australia
5/15
10
10
2004
Azerbaijan
10
10
10
1999
Belgium
10
0/10
0
2001
Belarus
15
10
10
1999
Bulgaria
15
15
15
1996
Canada
10/15 (2)
10
0/10
1998
China
10
10
10
1998
Croatia
5/10
10
10
1998
Cyprus
5/10 (3)
0
0
2000
Czech Republic
10
0
10
1998
Denmark
10
0
0
1998
Egypt
10
15
15
2001
Finland
5/12 (4)
0
0
2003
France
5/10/15 (5)
0
0
2000
Germany
5/15 (6)
0
0
1997
Greece
5/10
7
7
2008
Hungary
10
0
0
1998
Iceland
5/15
0
0
2004
India
10
10
10
1999
Indonesia
15
15
15
2003
Iran
5/10
7.5
5
2003
Ireland
10
0
0
1996
Israel
10
10
10
2001
Italy
5/10 (7)
10
0
1999
Japan
15/10
10
0/10 (8)
1987
Khazakhstan
10
10
10
1998
Korea
5/10 (9)
0
5
2001
Kyrgyz Republic
10
10
10
2001
Kuwait
5
0
10
2004
Lebanon
10
5
5
2001
Lithuania
5/10
10
5/10
2006
Luxembourg
10/15 (10)
0
0
1998
Macedonia
10
10
10
2001
Malaysia
15
15
10/15
1989
Mali
10/15
15
0
2000
Mexico
10
10
10
2009
Morocco
5/10
10
10
2000
Moldova
10
0
10
1998
Mongolia
10
10
0
1998
Namibia
5/10
10
5
2001
Netherlands
5/15 (11)
0
0
1999
New Zealand
15
10
10
2004
North Korea
10
0
0
2001
Norway
10
0/10 (12)
0
2003
Poland
10
10
10
1994
Portugal
10/15 (13)
10
10
2003
Philippines
15
15
15
2003
Qatar
5
5
5
2001
Romania
15
15
10
1996
Serbia & Montenegro
5/15
10
10
1998
Singapore
5/10
0/7.5
7.5
2009
Slovak Republic
10
0
10
1998
Slovenia
10
10
10
1998
South Africa
10/15
10
0
2001
Spain
5/10/15 (14)
0/5 (15)
5
2001
Sri Lanka
10/15
10
10
2003
Sweden
5/15 (16)
0
0
1996
Switzerland
5/15 (17)
5/10 (18)
0
1998
Syria
15
10
4.5/13.5/18
2004
Tajikistan
5/10
10
0
2004
Thailand
15
0/10
15
2009
Turkey
10
10
10
2000
Turkmenistan
10
5
5
2000
Ukraine
5/15 (19)
10
10
2000
UK
10
0
0
1999
USA
5/10 (20)
0
0
1994
Uzbekhistan
10
0/10
0
1996
Vietnam
10/15
10
15
1997
Notes:
(1)
5% for 10% shareholders, otherwise 15%
(2) 10% for 10% shareholders, otherwise 15%
(3) 5% if initial investment greater than US$100,000,
otherwise 10%
(4) 5% for 30% shareholders, otherwise 12%
(5) 5% if investment not less than FFr 500,000 and
if the recipient pays tax; 10% if either is untrue;
otherwise 15%
(6) 5% for 10% shareholders, otherwise 15%
(7)
5% for10% shareholders, otherwise 10%
(8) 0% for royalties in respect of literary, artistic
or scientific works including films and tapes; 10%
for royalties in respect of any patent, trade mark,
design or model, plan, secret formula or process,
or industrial,
commercial or scientific equipment, or information
concerning industrial, commercial or scientific experience.
(9) 5% for 30% shareholders, otherwise 10%
(10) 10% for 30% shareholders, otherwise 15%
(11) 5% for 25% shareholders, otherwise 15%
(12) 0% for commercial loans in connection with a
delay of payment for goods, equipment and services;
otherwise 10%
(13) 10% for 25% shareholders, otherwise 15%
(14) 5% for participation of at least ECU100,000 and
if the dividends are exempt from tax in; 10% if either
condition is met; otherwise 15%
(15) 0% if the actual recipient of interest is the
government of the other contracting state, or for
long-term bank loans (exceeding 7 years); otherwise
5%
(16)
5% for 100% participation or 30% participation in
a joint venture; otherwise 15%
(17) 5% for 20% shareholders, otherwise 15%
(18) 5% for bank loans, otherwise 10%
(19) 5% for participation of at least US$50,000; otherwise
15%
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