Russia amends double tax treaties and reacts to COVID-19 obstacles

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Russia amends double tax treaties and reacts to COVID-19 obstacles

Sponsored by

sponsored-firms-kpmg.png
Russia has introduced a range of significant international and domestic tax policies since March.

Dmitry Garaev and Olga Wollny of KPMG Russia discuss how the results of Russia’s initial economic response to COVID-19, and discuss how the burden seems to be increasing on foreign investors.

As COVID-19 has spread across the world and the international community has braced itself for economic recession, Russia has been far from idle. Alongside other countries, various measures to support citizens and businesses – including certain tax breaks – have been announced and promptly adopted via respective legislation. In the few months since entering into law, the first results can already be observed. 

COVID-19 relief measures cater to SMEs

The pandemic has been a devastating blow to most businesses, but small and medium-sized enterprises (SMEs) have been hit especially hard. In view of this, the tax breaks implemented by Russia were mostly aimed at offering tax relief to SMEs. The measures include suspending fiscal audits, extending tax reporting and tax payment deadlines, and offering property and land tax incentives for lessors. SMEs operating in the so-called ‘most affected industries’ were also relieved from certain tax payments (except for VAT and personal income tax) for the second quarter of 2020. 

Certain categories of large taxpayers, the so-called entities ‘operating in the most affected industries’ (including air and auto transportation, tourism and non-food retail business), along with strategic, systemic and city-forming entities, have also received the opportunity to apply for extensions to their tax payment deadlines, taking into consideration the effect that the pandemic has had on their financial figures.

Nevertheless, the benefit from these tax breaks is ambiguous. Naturally, given the significant contraction in cash inflows, any extension to tax payment deadlines feels like a breath of fresh air. However, more targeted measures – such as tax relief – depend on various formal criteria (like the officially declared code of the company denoting its main type of economic activity; it being listed on the SMEs register, etc.) which do not always keep up with the rapidly changing business environments in which firms operate. Another drawback is that allocation of the tax breaks depends on the state’s understanding of the ‘most affected industries’ and does not consider any individual company’s decline in revenue or cash flows. 

Double tax treaty trouble

Moreover, at a time when the government is on the one hand trying to support Russian companies, it, on the other hand, seems to be increasing the tax burden on foreign investors. One of the measures announced in relation to this concerns alterations to the double tax treaties with Cyprus, Malta and Luxembourg. If the amendments are made, all dividend and interest payments made from Russia to these jurisdictions would be subject to the withholding of 15% income tax. 

Malta and Russia were not able to agree on amicable amendments, and Russia has begun unliterally terminating the double tax treaty. Negotiations with Cyprus and Luxembourg are still under way. One can predict that the government may also seek to renegotiate its double tax treaties with other jurisdictions as well, such as the Netherlands, Singapore and Hong Kong SAR.

The bottom line is, as prompt as Russia was in reacting to the COVID-19 outbreak and its implications, the state’s domestic tax policy initiatives have been characterised by their moderation, while some have been controversial. Russia’s international tax policy, however, has been more or less straight-forward. The outcome of this policy’s moves remains to be seen.

Dmitry Garaev

E: dgaraev@kpmg.ru

Olga Wollny

E: owollny@kpmg.ru

more across site & shared bottom lb ros

More from across our site

New research, which suggests LLMs can silently corrupt complex documents, should alert tax and legal teams relying on AI to handle iterative drafting and compliance workflows
Maintaining increased funding for HMRC is a ‘high possibility’ if he becomes PM, ITR has also heard
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The firm has hired a team of private client lawyers from Withers to launch in New York and Connecticut, though ITR analysis suggests it faces stiff competition
The ability of tax authorities to receive and analyse data is becoming ‘quite advanced’, warns Stuart Lang, head of EY’s compliance co-sourcing solution
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
Despite the Netherlands featuring an unusual concentration of World Tax-ranked technology-led providers, sources believe there’s a long way to go to challenge the established players
Ethics seems to be playing a subservient role to an entitlement culture borne out of a pervasive ‘revenue at all costs’ mentality at the big four
Historical World Tax data suggests the ‘largest law firm merger in history’ may not pose a serious threat to the world's leading tax practices
The repeal of Libya’s statute of limitations and tougher enforcement leave taxpayers navigating a high-stakes choice between conciliation and litigation
Gift this article