As previously reported (see our review https://nplaw.ru/blog/detail/priostanovleno-deystvie-ryada-mezhdunarodnykh-nalogovykh-soglasheniy/), a number of double tax treaties with unfriendly countries have been suspended. However, the Ministry of Finance of the Russian Federation in its Information Letter added an exception to the suspension. If income in the form of interest is paid to export credit agencies or banking organizations in unfriendly countries, tax agents are entitled to continue not to calculate and not withhold income tax on such interest income (or withhold it at a reduced rate).
Nadmitov, Ivanov & Partners Law Firm will monitor the development of the situation and will notify about the adoption of the relevant federal law, as well as response measures from countries. Our Firm will help you optimize your income structure in a way that minimizes the impact of tax treaty suspensions.
See Information letter of the Ministry of Finance of the Russian Federation on the procedure for taxation of certain types of interest income paid to residents from unfriendly countries dated 11 August 2023 (https://minfin.gov.ru/ru/press-center/?id_4=38634-o_poryadke_nalogooblozheniya_otdelnykh_vidov_protsentnykh_dokhodov_vyplachivaemykh_rezidentam_iz_nedruzhestvennykh_stran)
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