Russia has unilaterally suspended the majority of provisions in its double taxation agreements. Most of the 1994 UK/Russia double taxation convention has been put on hold, including the treatment of dividends, interest, royalties, capital gains, business profits, employment income and pensions, and protection against discrimination. Provision for the elimination of double taxation is not fully suspended, but HMRC notes that it seems likely that ‘Russia will not honour any agreed limits on what it may tax at source, and that only limited relief from double taxation will be available in Russia’. The convention does not provide for unilateral action.
Russia has unilaterally suspended the majority of provisions in its double taxation agreements. Most of the 1994 UK/Russia double taxation convention has been put on hold, including the treatment of dividends, interest, royalties, capital gains, business profits, employment income and pensions, and protection against discrimination. Provision for the elimination of double taxation is not fully suspended, but HMRC notes that it seems likely that ‘Russia will not honour any agreed limits on what it may tax at source, and that only limited relief from double taxation will be available in Russia’. The convention does not provide for unilateral action.
