Tax perspectives for Russian companies in respect of the Russian-Netherlands double tax treaty denunciation
September 21, 2021
September 21, 2021
Since April 2020, the Russian Federation has been taking actions to increase tax rates for several types of income under double taxation treaties (DTTs) with jurisdictions that the Russian government recognizes as mainly used for holding activities. The Netherlands was named among such jurisdictions and in August 2020, Russia conditioned the Netherlands to either increase the withholding tax rates for dividend and interest income to 15% (with minor exceptions) or to denounce the DTT completely.
After several months of discussions, the Russian Ministry of Finance reported that negotiations with the Netherlands were unsuccessful. A couple of months later in May 2021, Russia signed a law denouncing the DTT with the Netherlands. In June 2021, the Russian Ministry of Foreign Affairs completed the DTT denunciation procedures under article 31 by providing notice to the Netherlands.
Thus, the DTT with Netherlands, one of the most popular jurisdictions among multinational groups to structure their business in Russia, will terminate on January 1, 2022.
Andrey Grachev | +7 495 662 6434 | Email
Ivan Koreshkov | +7 495 662 6434 | Email
___
If you have any questions about this legal alert, please feel free to contact any of the attorneys listed under Related People/Contributors or the Eversheds Sutherland attorney with whom you regularly work.
Insights
Getting over the starting line: How multi-entity organizational structures ...
Insights
Spate of “surprise” ticket fee class actions target New York venues
Insights
Preparation Guidance for Corporate Counsel to Meet SEC’s Climate Disclosure...
Insights
Horizon Scanner: Financial Crime - US wide developments
News
Eversheds Sutherland advises The Navigator Company, S.A. on its £127.5m rec...
News
Eversheds Sutherland Advises Sunergy Renewables on Completed Business Combi...
News
Eversheds Sutherland helps Exa Robotic Systems Ltd pave way to creating wor...
News
Eversheds Sutherland advises on UK’s second pension superfund transaction
Events And Training
Introduction to Dutch employment law
April 16, 2024
09.30am - 4.30pm (BST)
London, United Kingdom
Events And Training
French employment law training
April 17, 2024
2pm - 5pm (BST)
Virtual
Events And Training
The Energy Transition Series The role of Carbon Capture, Utilization, and S...
April 17, 2024
10:00 ET | 15:00 BST | 16:00 CET
Events And Training
Immigration UK Business – sponsor licencing course
April 23, 2024
09:30am - 11:30am (BST)
Virtual, United Kingdom