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Russia: Double Tax Treaties

Introduction

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which the former USSR was party are honored by Russia, unless the other party to the treaty has renounced it or it has been replaced by a new treaty.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.

Latest Russia Treaty Updates

Treaty Update: Russia - Japan
09 June, 2017
The Russian Government has announced that it intends to soon sign a DTA with Japan.
Treaty Update: Cyprus - Russia
20 January, 2017
During recent negotiations, Cyprus and Russia agreed to postpone the implementation of a Protocol to their double tax agreement.
Treaty Update: Russia - Cyprus
06 January, 2017
Russia and Cyprus have agreed to delay placing into effect a Protocol to their DTA, the Cypriot Ministry of Finance confirmed on December 29.
Treaty Update: Russia - Singapore
09 December, 2016
A Protocol to the Russia-Singapore DTA entered into force on November 25.
Treaty Update: Hong Kong - Russia
16 August, 2016
The DTA between Hong Kong and Russia became effective on July 29, 2016.
Treaty Update: Russia - Hong Kong
19 July, 2016
On July 3, 2016, Russia ratified a DTA with Hong Kong through law No. 234-FZ.
Treaty Update: Russia - China
05 February, 2016
Russia's lower house of Parliament on January 27, 2016, approved a law to ratify the 2014 DTA with China.
Treaty Update: Hong Kong - Russia
25 January, 2016
Hong Kong and Russia signed a comprehensive DTA on January 18, 2016.
Treaty Update: China - Russia
04 June, 2015
China and Russia signed a DTA on May 8, 2015.
Treaty Update: Russia - China
25 March, 2015
The Russian Government confirmed on March 18, 2015, that it has agreed to sign a Protocol with China to amend their DTA.
Treaty Update: China - Russia
16 October, 2014
China signed a new DTA with Russia on October 13, 2014.
Treaty Update: Malta - Russia
12 May, 2014
The DTA between Malta and Russia will enter into force on May 22, 2014.
Treaty Update: Russia - Malta
07 April, 2014
Russia completed its domestic ratification procedures in respect of the DTA signed with Malta on April 2, 2014.
Treaty Update: Russia - China
18 February, 2014
Russia on February 5, 2014, completed the drafting of a new DTA with China to replace their 1994 pact, the Russian Government said on February 15, 2014.
Treaty Update: Russia - Various
10 February, 2014
Russia's draft DTAs with Belgium and China were tabled before Russia's Cabinet for its approval on February 5, 2014.
Treaty Update: Russia - Malta
06 January, 2014
According to preliminary media reports, the DTA signed between Russia and Malta was forwarded to Russia's lower house of parliament on December 31, 2013, for its approval.
Treaty Update: Fiji - Russia
02 July, 2013
Fiji and Russia have announced their intention to commence negotiations towards a DTA, it was announced at bilateral meetings in Fiji beginning on June 28, 2013.
Treaty Update: Russia - United Arab Emirates
12 June, 2013
Russia on June 9, 2013, ratified the DTA signed with the United Arab Emirates on December 7, 2011.
Treaty Update: Russia - Malta
29 April, 2013
Malta and Russia signed a DTA on April 24, 2013.
Treaty Update: Armenia - Russia
28 February, 2013
Armenia's parliament on February 26, 2013, approved a law to ratify the Protocol to the Armenia-Russia DTA signed on October 24, 2011. Russia has already completed its domestic ratification procedures in respect of the agreement.
Treaty Update: Russia - Armenia
05 February, 2013
Russia on February 1, 2013, completed its domestic ratification procedures in respect of the DTA Protocol Russia signed with Armenia on October 24, 2011. The DTA was approved by the State Duma on January 18, 2013, and the Federal Council on January 23, 2013, and the Law was then signed by President Putin.
Treaty Update: Russia - Armenia
25 January, 2013
Russia's lower house of parliament approved a law on January 18, 2013, ratifying the Protocol that amends the 1996 DTA between Russia and Armenia.
Treaty Update: Luxembourg - Russia
08 January, 2013
The website of the Kremlin confirmed on January 2, 2013, that Russian President Vladimir Putin has signed a law ratifying the Protocol to Russia's DTA with Luxembourg, which was signed on November 21, 2011.
Treaty Update: Russia - Latvia
21 November, 2012
According to preliminary media reports, the Russia-Latvia DTA, signed in 2010, entered into force on November 6, 2012.
Treaty Update: Latvia - Russia
12 November, 2012
The Latvian government has confirmed that the Russian authorities have notified it of the completion of the nation's domestic ratification procedures, allowing the Russia-Latvia DTA, signed on December 20, 2010, to enter into force on November 6, 2012.
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