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Russia: Double Tax Treaties

Table Of Treaty Rates

Provided by TreatyPro
Russia


Jurisdiction Status Dividends Interest Royalties Notes
           
Defaults 15% 20% 20%
           
Albania Effective January 1, 1998 10% 10% 10%
Algeria Effective January 1, 2009 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government 15% 15%
Argentina Effective January 1, 2013 10% where the payee is a company holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 15% 15%
Armenia Effective January 1, 1999 5% where the payee has contributed a minimum of USD40,000 or equivalent to the paying company's capital 10% 0% 0%
Australia Effective January 1, 2004 5% when paid out of profits which have borne the normal company tax rate to a company (excluding a partnership) holding directly at least 10% of the paying company's capital with a minimum investment of AUD700,000 or equivalent 15% 10% 10%
Austria Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 0% 0%
Azerbaijan Effective January 1, 1999 10% 0% when paid to the government 10% 10%
Belarus Effective January 1, 1998 15% 0% when paid to the government 10% 10%
Belgium Effective January 1, 2001 10% 0% when paid to the government, or on a loan or credit guaranteed or insured by the government, or on a bank loan not represented by bearer instruments 10% 0%
Botswana Effective January 1, 2010 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank 10% 10%
Brazil Signed November 22, 2004 10% where the payee is a company holding directly at least 20% of the paying company's capital 15% 0% when paid to the government, or on government bonds, securities or debentures 15% 15% Not yet in force. Default rates apply.
Bulgaria Effective January 1, 1996 15% 0% when paid to the government 15% 15%
Canada Effective January 1, 1998 10% where the payee is a company holding at least 10% of the paying company's voting stock (or capital if there is no voting stock) 15% 0% when paid by the government, or to the central bank, or on a loan or credit financed, guaranteed or insured by a government approved institution 10% 0% for the use of any literary, artistic, dramatic or musical copyright (excluding broadcasting royalties), computer software or patent, or information concerning industrial, commercial or scientific experience (excluding a rental or franchise agreement) 10%
Chile Effective January 1, 2013 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 15% 5% for equipment royalties 10%
China Effective January 1, 1998 Replacement treaty signed October 13, 2014 10% When new treaty is effective: 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of EUR80,000 or equivalent 10% 0% when paid to the government or the central bank 10% When new treaty is effective: 0% when paid to the government or the central bank, or on a loan guaranteed or insured by the government or the central bank 5% 10% When new treaty is effective: 6% New treaty not yet in force
Croatia Effective January 1, 1998 5% where the payee is a company holding directly at least 25% of the paying company's capital with a value of at least USD100,000 or equivalent 10% 10% 10%
Cuba Effective January 1, 2011 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government, or on financing approved by both governments 10% 0% for literary, artistic or dramatic copyright royalties (excluding broadcasting royalties) 5%
Cyprus Effective January 1, 2000 Protocol effective January 1, 2013 5% where the payee has contributed a minimum of EUR100,000 or equivalent to the paying company's capital 10% 0% 0%
Czech Republic Effective January 1, 1998 Protocol effective January 1, 2010 10% 0% 10%
Denmark Effective January 1, 1998 10% 0% 0%
Egypt Effective January 1, 2001 10% 0% when paid to the government 15% 15%
Estonia Signed November 5, 2002 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD75,000 or equivalent 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 10% Not yet in force. Default rates apply.
Ethiopia Signed November 26, 1999 5% 5% 15% Not yet in force. Default rates apply.
Finland Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 30% of the paying company's capital with a minimum investment of USD100,000 or equivalent 12% 0% 0%
France Effective January 1, 2000 5% where the payee has contributed a minimum of FR500,000 or equivalent to the paying company's capital, and the payee is exempt from tax on the dividends (1) 10% where only one of the above conditions is fulfilled 15% 0% 0%
Germany Effective January 1, 1997 Protocol effective January 1, 2010 5% where the payee is a company holding directly at least 10% of the paying company's capital with a value of at least EUR80,000 or equivalent 15% 0% 0%
Greece Effective January 1, 2008 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 7% 7%
Hungary Effective January 1, 1998 10% 0% 0%
Iceland Effective January 1, 2004 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 0% 0%
India Effective January 1, 1999 10% 0% when paid to the government or the central bank 10% 10%
Indonesia Effective January 1, 2003 15% 0% when paid to the government or the central bank 15% 15%
Iran Effective January 1, 2003 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 10% 7.50% 5%
Ireland Effective January 1, 1996 10% 0% 0%
Israel Effective January 1, 2001 10% 0% when paid to the government or the central bank, or on a loan or credit guaranteed, insured or indirectly financed by the government or the central bank 10% 10%
Italy Effective January 1, 1999 5% where the payee is a company holding at least 10% of the paying company's capital with a value of at least USD100,000 or equivalent 10% 10% 0%
Japan Effective January 1, 1987 15% 0% when paid to the government or the central bank, or on a loan or credit guaranteed, insured or indirectly financed by the government or the central bank 10% 0% for copyright or broadcasting royalties 10% The USSR treaty continues to apply.
Kazakhstan Effective January 1, 1998 10% 0% when paid to the government, or on a bank loan 10% 10%
Korea, North Effective January 1, 2001 10% 0% 0%
Korea, South Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 30% of the paying company's capital with a minimum investment of USD100,000 or equivalent 10% 0% 5%
Kuwait Effective January 1, 2004 0% where the payee is the government or the central bank 5% 0% 10%
Kyrgyzstan Effective January 1, 2001 10% 0% when paid to the government or the central bank 10% 10%
Laos Signed May 14, 1999 10% 10% 0% Not yet in force. Default rates apply.
Latvia Effective January 1, 2013 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD75,000 or equivalent 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 5% when paid on a bank or financial institution loan to a bank or financial institution 10% 5%
Lebanon Effective January 1, 2001 10% 0% when paid to the government 5% 5%
Lithuania Effective January 1, 2006 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD100,000 or equivalent 10% 0% when paid to the government or the central bank, or on a loan guaranteed by the government 10% 5% for equipment royalties 10%
Luxembourg Effective January 1, 1998 Protocol effective January 1, 2014 5% where the payee is a company holding directly at least 10% of the paying company's capital with a value of at least EUR80,000 or equivalent 15% 0% 0%
Macedonia Effective January 1, 2001 10% 10% 10%
Malaysia Effective January 1, 1989 15% 0% when paid to the government or the central bank, or on a loan financed, guaranteed or insured by the government 15% 10% 15% for literary or artistic copyrights or broadcasting royalties The USSR treaty continues to apply.
Mali Effective January 1, 2000 10% where the payee has contributed a minimum of FR1m or equivalent to the paying company's capital (1) 15% 0% when paid by the government, or to the government or the central bank, or on financing approved by both governments 15% 0%
Malta Effective January 1, 2015 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of EUR100,000 or equivalent 10% 5% 5%
Mauritius Signed August 24, 1995 5% where the payee has contributed a minimum of USD500,000 or equivalent to the paying company's capital 10% 0% 0% Not yet in force. Default rates apply.
Mexico Effective January 1, 2009 10% 0% when paid to or by the government or the central bank, or on a loan or credit financed, guaranteed or insured for at least three years by a specified institution 10% 10%
Moldova Effective January 1, 1998 10% 0% 10%
Mongolia Effective January 1, 1998 10% 0% when paid to the government or the central bank 10% 20% (2)
Morocco Effective January 1, 2000 5% where the payee has contributed a minimum of USD50,000 or equivalent to the paying company's capital 10% 10% 10%
Namibia Effective January 1, 2001 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD100,000 or equivalent 10% 0% when paid to the government 10% 5%
Netherlands Effective January 1, 1999 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of EUR75,000 or equivalent 15% 0% 0%
New Zealand Effective January 1, 2004 15% 10% 10%
Norway Effective January 1, 2003 10% 0% when paid to the government or the central bank, or on sales on credit of equipment, goods, merchandise or services 10% 0%
Oman Signed November 26, 2001 5% where the payee has contributed a minimum of USD500,000 or equivalent to the paying company's capital 10% 0% 5% Not yet in force. Default rates apply.
Philippines Effective January 1, 1998 15% 0% when paid to the government 15% 15%
Poland Effective January 1, 1994 10% 0% when paid to the government or the central bank 10% 10%
Portugal Effective January 1, 2003 10% where the payee is a company holding directly at least 25% of the paying company's capital for 24 months before payment of the dividend 15% 0% when paid to or by the government 10% 10%
Qatar Effective January 1, 2001 5% 0% when paid to the government 5% 0%
Romania Effective January 1, 1996 15% 0% when paid to the government, the central bank or a specified institution 15% 10%
Saudi Arabia Effective January 1, 2011 0% where the payee is the government or the central bank 5% 0% when paid to or by the government, or on a loan approved by both governments 5% 10%
Montenegro Effective January 1, 1998 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 10% 10%
Singapore Effective January 1, 2010 5% where the payee is a company holding directly at least 15% of the paying company's capital with a minimum investment of USD100,000 or equivalent, or the government 10% 0% when paid to the government 7.5% 7.50%
Slovakia Effective January 1, 1998 10% 0% 10%
Slovenia Effective January 1, 1998 10% 10% 10%
South Africa Effective September 1, 2000 10% where the payee is a company holding at least 30% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 0% when paid on a loan financed or guaranteed by the government or the central bank 10% 0%
Spain Effective January 1, 2001 5% where the payee (excluding a partnership) has contributed a minimum of EUR100,000 or equivalent to the paying company's capital, and the dividends are exempt from tax 10% where only one of the above conditions is fulfilled 15% 0% when paid to the government, or on a bank or credit institution loan financed for at least seven years 5% 5%
Sri Lanka Effective January 1, 2003 10% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital 15% 0% when paid to the government or the central bank 10% 10%
Sweden Effective January 1, 1996 5% where the payee is a company (excluding a partnership) holding directly at least 100% (30% in the case of a joint venture) of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 0% 0%
Switzerland Effective January 1, 1998 Protocol effective January 1, 2013 0% where the payee is the government, the central bank or a pension fund 5% where the payee is a company (excluding a partnership) holding directly at least 20% of the paying company's capital with a minimum investment of CHF200,000 or equivalent 15% 0% 0%
Syria Effective January 1, 2004 15% 0% when paid to the government 10% 4.5% for broadcasting royalties 13.5% for copyright royalties 18%
Tajikistan Effective January 1, 2004 5% where the payee is a company holding directly at least 25% of the paying company's capital 10% 0% when paid to the government or the central bank, or on sales on credit of equipment, goods or services 10% 0%
Thailand Effective January 1, 2010 15% 0% when paid to the government or the central bank 10% when paid to a financial institution or insurance company 20% (2) 15%
Turkey Effective January 1, 2000 10% 0% when paid to the government or the central bank 10% 10%
Turkmenistan Effective January 1, 2000 10% 5% 5%
Ukraine Effective January 1, 2000 5% where the payee has contributed a minimum of USD50,000 or equivalent to the paying company's capital 15% 0% when paid to the government or the central bank, or on credits guaranteed by the government or the central bank 10% 10%
United Kingdom Effective January 1, 1998 10% 0% 0%
United States Effective February 1, 1994 5% where the payee is a company holding at least 10% of the paying company's voting stock (or capital if there is no voting stock) 10% 0% 0%
Uzbekistan Effective January 1, 1996 10% 0% when paid to the government or the central bank, or on sales on credit of equipment, goods or services 10% 0%
Venezuela Effective January 1, 2010 10% where the payee is a company (excluding a partnership) holding directly at least 10% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 0% when paid to or by the government or the central bank, or on a loan financed or guaranteed by a financial institution to promote exports and development 5% when paid to a bank 10% 15%
Vietnam Effective January 1, 1997 10% where the payee has contributed a minimum of USD10m or equivalent to the paying company's capital 15% 10% 15%
Serbia Effective January 1, 1998 5% where the payee is a company (excluding a partnership) holding directly at least 25% of the paying company's capital with a minimum investment of USD100,000 or equivalent 15% 10% 10%

Footnotes

  1. The currency stated in the treaty has been replaced by the Euro and should be calculated as such.
  2. The domestic rate applies.
  3. PLEASE NOTE: This table was last updated February 2015

 

 

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