Attn.: NSD's Clients
Please be advised that, due to the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), Double Taxation Treaties will be applicable subject to the MLI provisions with effect from 1 January 2021.
To understand whether the rules of taxation applicable to international transactions with a particular jurisdiction have changed, it is necessary to see whether the MLI has taken effect for that jurisdiction and what reservations had been made upon ratification of the MLI with respect to that jurisdiction's Double Taxation Treaty with Russia.
For MLI-related materials, please see the OECD website: www.oecd.org/tax/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-beps.htm, including the MLI Matrix of Options and Reservations at https://www.oecd.org/tax/treaties/mli-database-matrix-options-and-reservations.htm, and the MLI Matching Database at https://www.oecd.org/tax/treaties/mli-matching-database.htm.
If you have any questions related to this communication, please contact your account managers by telephone: +7 495 956-27-90/91