By decree, some of the provisions of the double taxation agreement with Germany are suspended. However, double taxation of income will not take place.

The Russian President signed Decree No. 585 of 8 August 2023 suspending tax treaties with 38 countries. This includes the agreement between Germany and Russia on the avoidance of double taxation in the field of taxes on income and assets (DTA). However, some provisions remain in force:

– Possibility of crediting income tax paid in one state against income tax paid in the other state;

– Exchange of tax information;

– Mutual agreement procedure.

For companies, this means the abolition of reduced tax rates on dividend distributions and, in principle, Russian withholding tax on interest and royalties of 20 per cent. In addition, the free availability of capital for foreign companies and their subsidiaries will be restricted.

Already on 15 March 2023, the Russian Ministry of Finance and Foreign Affairs proposed a suspension of the double taxation agreement with countries that have imposed sanctions against Russia. Furthermore, in February 2023, the EU put Russia on a blacklist of countries that do not cooperate with the EU. The list serves to combat tax evasion and tax avoidance. It mainly includes countries that have not fulfilled their obligations to act responsibly in the tax area.

On the subject:

– GTAI article Russia to suspend double taxation agreement with the West from 17 March 2023 (german language only) go to: Russland will Doppelbesteuerungsabkommen mit dem Westen aussetzen | Wirtschaftsumfeld | Russland | Steuern (gtai.de)

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