Please be advised that the List of Tax Rates and References under Double Taxation Treaties of the Russian Federation available on NSD's official web site (“Tax Management” page) have been updated with regard to international treaties concluded with Japan and Ecuador:
- due to the receipt of the official clarification from Russia’s Ministry of Finance regarding the application of paragraph 1 article 11 of the Convention between the Government of Japan and the Government of the Russian Federation for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance;
- due to the completion of ratification procedures by Russian and Ecuadorian parties and to the entry into force of the international treaty between the two countries’ Governments in 2019.
The letter of the Ministry of Finance No. 03-08-05/19055 (dated 21 March 2019) which clarifies the issue of the application of provisions of paragraph 1 article 11 of the Convention between the Government of Japan and the Government of the Russian Federation is available on NSD's official web site (“Tax Management” page, “Clarifications from the Ministry of Finance” section).
Please be advised that pursuant to the clarifications received, the tax benefit may be applied in accordance with paragraph 1 article 11 of the Convention between the Government of Japan and the Government of the Russian Federation strictly if certain terms described in article 21 of the Convention are observed.
A tax disclosure example for the use of the tax benefit under paragraph 1 article 11 of the Convention between the Government of Japan and the Government of the Russian Federation is available on NSD's official web site (“Tax Management” page, “Tax Disclosure Examples” section).
In case of any question related to this communication, you may contact your account managers at +7 495 956-27-90, +7 495 956-27-91.