The meaning of the double tax treaty. Use of double taxation agreements by Russian companies. Certificate confirming residence of the Russian Federation

12.01.2024 | Muscles

Receiving income from a source abroad is often associated with the need to pay “profitable” tax according to the rules of local tax legislation. But the mere fact of paying a foreign tax does not relieve a resident of the Russian Federation from the need to pay the budget of his native state. However, situations where the same income is subject to taxation twice do not always arise. The Russian Federation has agreements for the avoidance of double taxation with a number of countries. These documents provide for the collection of tax only once, and do not double the mandatory deductions from income received from foreign economic transactions.

With which countries has a double tax treaty been concluded?

Potentially, any income taxes can be “doubled” - personal income tax, income tax, simplified tax on the simplified tax system, if the source of payment of income is a foreign payer, and the recipient is a resident of the Russian Federation. Each country has its own laws related to the procedure for calculating taxes. Accordingly, income abroad can be taxed at very different rates, regardless of what tax and at what rate the same income may be subject to in Russia.

But, focusing on the method of eliminating double taxation, based on work within the framework of the relevant agreement, a company, individual entrepreneur or individual will not pay a double amount of budget deductions. Of course, if the deal is concluded with a representative of the state in which the Russian Federation has this agreement.

At the moment, the Russian Federation has agreements with countries such as Belarus, Kazakhstan, Tajikistan, the USA, Canada, Germany, France, Israel, Egypt, Japan, China, Australia. In total, as of January 1, 2017, there are 82 such states with which we have agreements on the elimination of double taxation, and all of them are listed in the corresponding information letter from the Ministry of Finance.

Evidence of Resident Status

The issue of eliminating double taxation is especially relevant, perhaps, in relations with companies in nearby countries, for example, Kazakhstan and Belarus, since it is with them that Russian business has recently developed the closest ties. How does this work in practice?

Let’s assume that a Russian company provides certain services to an organization registered in Belarus, with which the Russian Federation has a corresponding agreement on the avoidance of double taxation.

When transferring payment in the described situation, the Belarusian party is obliged by default to withhold from the income of a foreign counterparty the amount of tax at a rate of 15% - it is established by the Tax Code of the Republic of Belarus. As a result, the executing company receives income minus the amount of tax, and in this case it no longer has to pay a repeated tax in Russia.

But there is another option - to provide the Belarusian counterparty with a certificate of residence in the Russian Federation. In this case, the customer company will have confirmation that the performing organization is indeed a Russian company and, therefore, subject to the agreement. Based on such a certificate, the income is transferred in full, without any deductions, and the Russian company will pay the budget in accordance with the Russian Tax Code. Moreover, if such a company operates within the framework of the simplified tax system - 6%, then paying tax with us is obviously more profitable, and vice versa, if it is a company on the general taxation system with a rate of 20%, the tax amount will be higher if it is paid to the budget of the Russian Federation .

One way or another, a residence certificate is a document on the basis of which a foreign partner does not tax the amount of income paid to a Russian organization in accordance with the taxes in force in its territory.

Certificate confirming residence of the Russian Federation

The procedure for confirming the status of a resident of the Russian Federation was approved in the Information message of the Federal Tax Service of Russia dated November 23, 2012. Since February 2008, the Interregional Inspectorate of the Federal Tax Service of Russia for Centralized Data Processing, abbreviated as MI Federal Tax Service of Russia for Data Centers, has been processing documents confirming this status.

There is no request form for confirmation of resident status - firms, individual entrepreneurs and individuals draw it up in free form, but with the obligatory indication of the calendar year for which confirmation is required, the name of the foreign state with whose representative there is cooperation, as well as the name and details of the Russian taxpayer itself.

In most cases, a certificate of the established form is issued to confirm the status of a Russian resident. However, depending on which country the domestic company works with, this may also be a form of document approved by a foreign state. In such cases, the form is certified by the signature of the official and the seal of the Russian tax authority.

The procedure itself is quite lengthy. The period for consideration of applications for issuance of confirmation of resident status is 30 calendar days from the date of submission to the MI of the Federal Tax Service of Russia at the data center of the request, as well as additional necessary documents.

A certificate of confirmation of resident status is usually issued for the current calendar year, but it can also be requested for past periods.

The relevance of the topic of double taxation in Russia is explained by the fact that the collection system in all countries is different. Each state creates a system of taxes and fees only at its own discretion. Some require certain contributions from the entire world income of their residents, others adhere to the principle of territoriality and charge a certain amount from a transaction carried out within their state. It would be ideal if all countries adhered to one principle. This would greatly facilitate this system in the world both for the fiscal authorities themselves and for payers. But due to different levels of development and criteria for determining sources of income, this is impossible to do. A striking example is double taxation. At the moment, however, there are ways to eliminate this unpleasant moment. This article will look at double taxation in Russia and how it is eliminated.

What is included in this concept?

The taxation system allows for double collection. This definition implies the collection of taxes from a person simultaneously by two states. As mentioned above, there are two directions in which the work of fiscal authorities is carried out:

The principle of residence. In this case, the taxation system is aimed at maximizing the collection of funds. That is, the state does not care where any operation was carried out; according to the law, contributions must still go to the budget.
The principle of territoriality. Those states that adhere to this option are more loyal to the system of taxes and fees. According to regulations, they cannot claim economic transactions that took place outside the country.

How is this phenomenon classified depending on the principle of implementation?

Double taxation in Russia has its own division. It is not homogeneous and is carried out according to several classification criteria.

Depending on the principle of implementation of this process, it can be of the following types:

International double economic type. Its essence lies in the fact that fees are levied simultaneously on several entities, but those that are involved in the same economic transaction. That is, these individuals have a common income.
International double legal type. In this case, one subject owns any operation. The income received as a result is taxed by the fiscal services of several states at once.

This division also explains how to avoid double taxation. Regarding the first type, credit is applied on an initiative basis, which is carried out by its resident for fees paid abroad. In relation to the international dual legal type, it is recommended to formulate a set of special rules. This allows the jurisdiction of the two countries to be shared in relation to the transaction carried out. That is, for this it is necessary to establish a business relationship between the state in which the company is a resident and the country that is the source of income. These above methods of eliminating double taxation are quite effective. The governments of many countries enter into specialized agreements to eliminate this problem.

How is this phenomenon classified depending on the level?

There is one more classification feature. Depending on the level at which this procedure is carried out, it can be of the following types:

Interior. Double taxation in Russia and a number of other countries implies the collection of finances depending on the importance and level of the administrative-territorial unit. But at the same time, this process is carried out on each of them. It also has its own division depending on the channel. It can be vertical and horizontal. The first includes two types of taxes. One must be paid to the budget of the local fiscal service, and the second to the state. The peculiarity of the second is that the system of revenues and fees is determined independently in each administrative-territorial unit. That is, in some places the penalties apply to all types of income, in others - received only within its borders, and sometimes transactions carried out on the territory of the entire state are taken into account.
External. Double taxation in Russia can also have an international character. That is, in this situation there is a clash of national interests of two countries at the same time. Penalties are determined by the legislation of each. Codes of regulations distinguish the object that is taxed and the subject that must make a contribution. This person must be obligated to the other country as well.

What contradictions arise due to this phenomenon?

Elimination of double taxation is a priority for the fiscal services of various states. This helps establish contact between governments and reduce the number of disputes. This topic is very relevant at the moment, as it has actually become a global problem.

The content of this concept is very unclear and illogical for many people. Of course, one can understand those in power who want to attract more funds to the budget, while seizing every opportunity and using any means. But a person suffers in this situation, because he is forced to give part of his income to the fiscal services of two states at the same time, and in the same period of time.

Another challenge is balancing the relevant legal system. It must clearly highlight the very base that will become the object of collection. It is quite difficult to distinguish between so-called residents and non-residents, since this requires the classification of the income itself. The latter need to keep records and differentiate them based on territoriality and country registration.

The agreement on the avoidance of double taxation will thus help solve the problem of the difference in the forms of this process. After all, each state defines the object that will become a source of recovery in completely different ways. Back in the twentieth century, the League of Nations entrusted the solution of this issue to a group of scientists who developed certain recommendations. They are aimed at eliminating different interpretations of the rules and elements of this procedure.

What does the agreement include to avoid this phenomenon?

The use of a double taxation agreement is a very effective way to solve this problem. This agreement represents the consolidation of certain rules according to which the tax and fee systems of both countries operate. This agreement spells out the following clauses, identifying those entities that are obliged to pay contributions. The agreement applies to both individuals and organizations. A separate rule fixes the issue of assets that provide a certain income, but are not geographically located in the resident’s home state. The agreement on the avoidance of double taxation also provides for various types of taxes and fees and the circle of persons covered by payments. This is necessary in order to highlight those points for which the agreement is relevant. When concluding it, the period of validity of the document is prescribed, as well as the procedure for its implementation and termination. The agreements on the avoidance of double taxation that the Russian Federation concluded made it possible to solve the problem of fees simultaneously with eighty-two world powers.

Experts consider this way of solving the problem to be very beneficial for residents, because it allows them not to overpay twice. As for other countries, a completely different situation arises regarding the operations performed. That is, if in another state the fiscal service collects tax from a non-resident, then this will in no way be taken into account by a similar structure in Russia.

How does the agreement affect rental income collections?

The conclusion of this agreement is very important for those who have or are planning to purchase real estate abroad. This is explained by the fact that in this case the Russian fiscal service will count taxes on income from the rental or sale of property.

The law on double taxation implies that if income is derived from real estate located outside the territory of the Russian Federation, then the tax on it paid in another country is deducted from the Russian tax. In order to calculate the amount of finance that needs to be paid to the domestic fiscal service, it is necessary to perform the opposite action - that is, subtract thirteen percent established by law from the foreign amount. It follows from this that the difference cannot be negative, that is, the foreign tax cannot be less than the Russian one. Ultimately, it turns out that a person, in any case, must make payments in full, but part goes to the budget of one country, and part to another. This is in any case better than paying double the bets.

How to register rental income?

The Russian legal framework also stipulates that profits received from real estate located abroad in the form of rent must be officially declared. There is a special form 3-NDFL for this. In another way, it is the so-called sheet “B”. It records all income received outside the Russian Federation. A number of other documents must be attached to this document, which confirm the amount of profit and the fact that tax was paid in the territory of another country. This certificate must be translated and notarized. In addition to it, the package of documents also includes paper reflecting the type of income and its amount for the calendar year. It must contain information about the date and amount of collection. It is necessary to notarize both the copy of the tax return and the document confirming payment. This type of statement can be made within three years after receiving this profit.

It is important to remember that when going through the simplified taxation procedure, it is not possible to receive credit from another country. Payments in this case are made at a double rate.

How is tax deducted when making a profit from the sale of property abroad?

Art. 232 of the Tax Code of the Russian Federation provides for and takes into account taxes that were paid upon the sale of real estate outside the country. The letter approved in 2012 recorded the fact that the procedure for selling a house in Russia and abroad is no different. The rules apply equally to both cases.

According to the new rules, a person who has received compensation for the sale of an apartment is not required to pay fees in two cases. This setting applies to objects that came into the buyer’s possession before January 1, 2016. It must be owned by the previous owner for at least three years.

In the second case, there is no need to make contributions to the Russian fiscal service if the apartment was purchased after January 1, 2016. But there are a number of certain conditions. First, it must have been owned by the seller for at least five years. An exception is real estate that was inherited under a gift agreement from a relative or during an agreement for the lifelong maintenance of a dependent family member. In this situation, the minimum period is three years.

It is also important to remember the fact that such an exemption from paying fees is appropriate and legal only if the property was not used for business purposes.

How to register profits from sales?

In order to carry out this procedure, it is necessary to go through the following stages:

Make sure you meet the above conditions.
Prepare and submit a tax return. This must be done within the specified time frame. This is the thirtieth of April of the year following profit.
Deposit the collection amount into the fiscal service before July fifteenth of the current year.

A common point with taxation of rental income is that a double tariff is possible. It is carried out at a rate equal to thirteen percent.

How is business activity taxed in this case?

Entrepreneurial activity, according to any agreement, is carried out according to a single requirement. It states that taxes must be paid only to the country that is the source of the income, only under the following conditions:

the person who received the profit is not a resident in another state;
profit was received through a permanent establishment.

Only that part of the income that is obtained through the last paragraph is subject to taxation. We can talk about a permanent establishment only if a number of certain factors exist. Firstly, business activity must have a specific location. That is, it could be some kind of room or site. This very place should not be disposable. Of course, there are exceptions in the form of work that requires movement. In such a situation, the economic integrity of the project is taken into account.

The second condition is that commercial activity takes place - partially or in full - through this location. The place of activity of a representative office is not considered permanent if it is carried out through an agent who has a dependent status.

If the work is of an auxiliary or preparatory nature, then this also cannot be classified as a permanent establishment. It is considered that if the buildings are used solely for the purpose of storing, displaying, purchasing or supplying goods, then this does not entitle only one country to payment of tax. This applies even to those cases where the management of these objects is carried out through a permanent office. The income of this type of organization is not subject to foreign taxes.

16.05.2016

Applications of double taxation agreements concluded by the Russian Federation.

Currently, agreements on the avoidance of double taxation have been signed by Russia with more than 80 states. Among them are many EU countries, including Cyprus, Great Britain, Denmark, the Netherlands; Switzerland; USA; China; CIS countries, incl. Ukraine, Belarus, Kazakhstan; Baltic countries - Latvia, Lithuania and a number of others (see. List of existing agreements for the avoidance of double taxation).

IMPORTANT: If an international tax agreement provides for a different tax rate than that provided for by the Tax Code of the Russian Federation, then the rate specified in the double taxation agreement is applied!

Let us dwell on some of the most significant aspects of the application of international tax agreements in Russia.

Responsibilities of a tax agent

Responsibility for the correct calculation and withholding of tax at source (including the correct application of benefits (reduced rates and exemptions) provided for by international tax agreements lies with the tax agent.

According to the Tax Code of the Russian Federation, tax on income received by a foreign organization from sources in the Russian Federation calculated and withheld by a Russian organization (tax agent), paying income to a foreign organization, with each payment of income, in the currency of payment of income. The exception is when:

the income paid relates to the permanent establishment of the foreign organization receiving the income in the Russian Federation;
in relation to income paid to a foreign organization, Article 284 of the Tax Code of the Russian Federation provides for a tax rate of 0%;
income, in accordance with international treaties of the Russian Federation, is not taxed in the Russian Federation (subject to the foreign organization presenting to the tax agent the confirmation provided for in paragraph 1 of Article 312 of the Tax Code of the Russian Federation);
in some other cases provided for in paragraph 2 of Art. 310 Tax Code of the Russian Federation.

It should be remembered that unlawful failure to withhold and (or) transfer (incomplete withholding and (or) transfer) within the period established by the Tax Code of the Russian Federation of tax amounts subject to withholding and transfer by a tax agent constitutes a tax offense and entails a fine of 20 percent of the amount. subject to withholding and (or) transfer (Article 123 of the Tax Code of the Russian Federation), as well as penalties (on the issue of collecting penalties from a tax agent, see Resolution of the Presidium of the Supreme Arbitration Court of the Russian Federation No. 4047/06 of September 26, 2006).

Confirmation of the permanent location of a foreign organization

Subparagraph 4 of paragraph 2 of Article 310 of the Tax Code of the Russian Federation provides that in the event of a Russian organization paying income to a foreign organization for which, in accordance with international treaties (agreements), a preferential tax regime is provided in the Russian Federation, such income is exempt from withholding tax at the source of payment or withholding tax at source of payment at reduced rates, subject to presentation by the foreign organization to the tax agent confirmations, provided for in paragraph 1 of Article 312 of the Tax Code of the Russian Federation.

In accordance with paragraph 1 of Art. 312 of the Tax Code of the Russian Federation, the specified confirmation must meet the following requirements:

must be certified by the competent authority of the relevant foreign state,
if this confirmation is drawn up in a foreign language, the tax agent is also provided with a translation into Russian,
confirmation must be provided by the foreign organization before the date of payment of income.

Thus, if at the time of payment of income to a foreign organization, the Russian organization - the source of payment of income does not have the specified confirmation, then it is obliged to withhold tax at the source of payment at the rate established by law.

Moreover, if the specified confirmation appears at the disposal of the tax agent later, it is possible to refund the previously withheld tax on income paid to foreign organizations in accordance with clause 2 of Art. 312 of the Tax Code of the Russian Federation. To do this, the following documents must be submitted to the tax authority:

Application for refund of withheld tax in the prescribed form;

Confirmation that this foreign organization at the time of payment of income had a permanent location in the state with which the Russian Federation has an international treaty (agreement) regulating taxation issues;

Copies of the agreement (or other document) in accordance with which income was paid to a foreign legal entity, and copies of payment documents confirming the transfer of the amount of tax to be refunded to the budget;

An application for the return of amounts of taxes previously withheld in the Russian Federation, as well as other documents listed above, are submitted by the foreign recipient of income to the tax authority at the place of registration as a tax agent within three years from the end date in which the income was paid.

Status of “actual recipient of income” as a condition for applying benefits under double taxation agreements

When applying agreements on the avoidance of double taxation in terms of granting the right to use benefits (reduced rates and exemptions) when taxing certain types of income from sources in the Russian Federation, it is necessary to assess whether the person applying for the use of benefits (reduced rates and exemptions) , “the actual recipient (beneficial owner)” of the relevant income.

International tax treaties are based on the Model Convention on Taxes on Income and Capital) and on the official commentaries thereto, containing the interpretation of its provisions.

When applying the provisions of tax treaties, it is necessary to proceed from the fact that the term “actual recipient (beneficial owner) of income” is not used in a narrow technical sense, but should be understood based on the goals and objectives of international tax treaties, such as, for example, avoidance of double taxation and evasion from paying taxes, and taking into account such basic principles of treaties as prevention of abuse of treaty provisions and the predominance of substance over form. At the same time, the direct recipient of the income, although he may qualify as a resident, cannot for this reason alone by default be considered as the beneficial owner of the income received in the state of residence.

Providing tax benefits (reduced rates and exemptions) in the source state of income paid to a foreign person also contradicts the goals and objectives of international agreements if the recipient of such income, without formally using such instruments as agency or nominal holding, will act as an intermediate link in the interests of another the person actually benefiting from the relevant income. Such an intermediate link, for example a conduit company, cannot be considered as a person having an actual right to the income received, if, despite its formal status as the owner of income in a transaction with a person who is a tax resident of the state where the income is sourced, such a company has very narrow powers in relation to this income, which allows it to be considered as a fiduciary or manager acting on behalf of interested parties.

To recognize a person as the actual recipient of income (beneficial owner), it is necessary not only to have legal grounds for directly receiving income, but this person must also be direct, that is, the person who actually benefits from the income received and determines his future economic fate. When determining the actual recipient (beneficial owner) of income, one should also take into account the functions performed and risks assumed by the foreign organization applying for benefits in accordance with international tax treaties.

Provided for by double taxation agreements benefits (reduced rates and exemptions) in relation to paid income from a source in the Russian Federation do not apply if they are paid as part of a transaction or series of transactions carried out in such a way that foreign person applying for benefits in the form of a reduced rate of interest and royalties, pays directly or indirectly all or substantially all of the income (at any time and in any form) to another person who would not have received the benefits (reduced rates and exemptions) under the relevant tax treaty if such income was paid directly to such person.

Thus, the position of the Russian Ministry of Finance is that the benefits (reduced rates and exemptions) provided for by double taxation agreements when paying income in the form of dividends, interest and income from the use of copyrights from sources in the Russian Federation apply only if a resident of a foreign state with which Russia has concluded a corresponding agreement is the actual recipient of the income.

Application of double taxation agreements in other countries

“Classical” offshore zones rarely have concluded agreements for the avoidance of double taxation, which can be used to optimize the payment of income to non-resident entities. Therefore, low-tax and onshore jurisdictions, such as Cyprus, Great Britain, Denmark, the Netherlands, other European countries, etc., are suitable for the application of tax treaties.

Eg, Great Britain has the world's largest network of tax treaties (more than 100). However, the application of tax agreements is possible only if the company is not a nominee, that is, it is not an agent of the offshore principal company, which owns the majority of the profit (income) received. Only if the income is recognized as income of the English company can it claim to benefit from the agreement. Of course, it is impossible to apply a tax treaty by a company filing “sleeping reports” - dormant accounts. It is possible to use agreements in holding schemes.

One of the countries most suitable for the application of international tax agreements, as before, remains Republic of Cyprus(has more than 40 existing agreements). A tax residence certificate is issued by the Ministry of Finance at any time after company registration. An important condition for obtaining a certificate is the presence of local directors - residents of Cyprus.

Tax residency certificates are also issued in other jurisdictions. significant for tax planning (Denmark, the Netherlands, Luxembourg, Latvia, Malta and other countries). However, an important factor influencing the possibility of obtaining a tax certificate is whether the company has “real content” (substance) in the territory of the country of registration.

Criteria for such presence. which a company must meet in order to be considered a tax resident of its country may be the following:

presence of a real office at a real address in the country of registration of the company;
the presence of local directors (residents of the country of registration of the company) who manage the company in the territory of this country;
availability of a bank account (main) in a local bank;
storage of financial documentation and reporting in an office in the country of registration of the company;
availability of staff;
carrying out real activities, etc.

The extent of such presence may vary depending on the company's objectives (eg trading or holding activities).

In the table below you will find a list of countries with which Russia has a double tax treaty. Let's say your organization pays income to a company whose permanent location is located in another state. If Russia has an agreement on the avoidance of double taxation with this country, your company as a tax agent will be able to either not withhold tax on the income paid at all, or withhold it at a reduced rate (depending on the terms of the agreement between the countries).

List of current bilateral international treaties for the avoidance of double taxation

State	International treaty
Australia	Agreement between the Government of the Russian Federation and the Government of Australia of September 7, 2000 “On the avoidance of double taxation and the prevention of tax evasion in relation to income taxes”
Austria	Convention between the Government of the Russian Federation and the Government of the Republic of Austria of April 13, 2000 “On the avoidance of double taxation with respect to taxes on income and capital”
Azerbaijan	Agreement between the Government of the Russian Federation and the Government of the Azerbaijan Republic of July 3, 1997 “On the avoidance of double taxation in relation to taxes on income and property”
Albania	Convention between the Government of the Russian Federation and the Government of the Republic of Albania of April 11, 1995 “On the avoidance of double taxation with respect to taxes on income and property”
Algeria	Convention between the Government of the Russian Federation and the Government of the Algerian People's Democratic Republic of March 10, 2006 “On the avoidance of double taxation with respect to taxes on income and property”
Argentina	Convention between the Government of the Russian Federation and the Government of the Argentine Republic of October 10, 2001 “On the avoidance of double taxation with respect to taxes on income and capital”
Armenia	Agreement between the Government of the Russian Federation and the Government of the Republic of Armenia of December 28, 1996 “On the elimination of double taxation on income and property”
Belarus	Agreement between the Government of the Russian Federation and the Government of the Republic of Belarus of April 21, 1995 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and property.” An integral part of the Agreement is the Protocol of January 24, 2006.
Belgium	Convention between the Government of the Russian Federation and the Government of the Kingdom of Belgium of June 16, 1995 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and property”
Bulgaria	Agreement between the Government of the Russian Federation and the Government of the Republic of Bulgaria dated June 8, 1993 “On the avoidance of double taxation in relation to taxes on income and property”
Botswana	Convention between the Government of the Russian Federation and the Government of the Republic of Botswana of April 8, 2003 "On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income"
Brazil	Convention between the Government of the Russian Federation and the Government of the Federative Republic of Brazil of November 22, 2004 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income”
Great Britain	Convention between the Government of the Russian Federation and the Government of the United Kingdom of Great Britain and Northern Ireland of February 15, 1994 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital gains”
Hungary	Convention between the Government of the Russian Federation and the Government of the Hungarian Republic of April 1, 1994 “On the avoidance of double taxation with respect to taxes on income and property”
Venezuela	Convention between the Government of the Russian Federation and the Government of the Bolivarian Republic of Venezuela of December 22, 2003 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital”
Vietnam	Agreement between the Government of the Russian Federation and the Government of the Socialist Republic of Vietnam dated May 27, 1993 “On the avoidance of double taxation and the prevention of tax evasion in relation to income taxes”
Germany	Agreement between the Russian Federation and the Federal Republic of Germany of May 29, 1996 “On the avoidance of double taxation with respect to taxes on income and property”
Greece	Convention between the Government of the Russian Federation and the Government of the Hellenic Republic of June 26, 2000 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital”
Denmark	Convention between the Government of the Russian Federation and the Government of the Kingdom of Denmark of February 8, 1996 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and property”
Egypt	Agreement between the Government of the Russian Federation and the Government of the Arab Republic of Egypt dated September 23, 1997 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and capital”
Israel	Convention between the Government of the Russian Federation and the Government of the State of Israel of April 25, 1994 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income”
India	Agreement between the Government of the Russian Federation and the Government of the Republic of India of March 25, 1997 “On the avoidance of double taxation in relation to income taxes”
Indonesia	Agreement between the Government of the Russian Federation and the Government of the Republic of Indonesia dated March 12, 1999 “On the avoidance of double taxation and the prevention of income tax evasion”
Iran	Agreement between the Government of the Russian Federation and the Government of the Islamic Republic of Iran dated March 6, 1998 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and capital”
Ireland	Agreement between the Government of the Russian Federation and the Government of Ireland of April 29, 1994 “On the avoidance of double taxation in relation to income taxes”
Iceland	Convention between the Government of the Russian Federation and the Government of the Republic of Iceland of November 26, 1999 “On the avoidance of double taxation and the prevention of income tax evasion”
Spain	Convention between the Government of the Russian Federation and the Government of the Kingdom of Spain of December 16, 1998 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital”
Italy	Convention between the Government of the Russian Federation and the Government of the Italian Republic of April 9, 1996 “On the avoidance of double taxation with respect to taxes on income and capital and the prevention of tax evasion”
Kazakhstan	Convention between the Government of the Russian Federation and the Government of the Republic of Kazakhstan of October 18, 1996 “On the elimination of double taxation and the prevention of tax evasion on income and capital”
Canada	Agreement between the Government of the Russian Federation and the Government of Canada of October 5, 1995 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and property”
Qatar	Agreement between the Government of the Russian Federation and the Government of the State of Qatar of April 20, 1998 “On the avoidance of double taxation with respect to income taxes”
Cyprus	Agreement between the Government of the Russian Federation and the Government of the Republic of Cyprus of December 5, 1998 “On the avoidance of double taxation in relation to taxes on income and capital”
Kyrgyzstan	Agreement between the Government of the Russian Federation and the Government of the Kyrgyz Republic of January 13, 1999 “On the avoidance of double taxation and the prevention of income tax evasion”
China	Agreement between the Government of the Russian Federation and the Government of the People's Republic of China of May 27, 1994 “On the avoidance of double taxation and the prevention of tax evasion in relation to income taxes”
DPRK	Agreement between the Government of the Russian Federation and the Government of the Democratic People's Republic of Korea dated September 26, 1997 “On the avoidance of double taxation with respect to taxes on income and capital”
Korea	Convention between the Government of the Russian Federation and the Government of the Republic of Korea of November 19, 1992 “On the avoidance of double taxation with respect to taxes on income”
Cuba	Agreement between the Government of the Russian Federation and the Government of the Republic of Cuba of December 14, 2000 “On the avoidance of double taxation and the prevention of tax evasion on income and capital”
Kuwait	Agreement between the Russian Federation and the State of Kuwait of February 9, 1999 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and capital”
Latvia	Agreement between the Government of the Russian Federation and the Government of the Republic of Latvia dated December 20, 2010 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and capital”
Lebanon	Convention between the Government of the Russian Federation and the Government of the Lebanese Republic of April 8, 1997 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income”
Lithuania	Agreement between the Government of the Russian Federation and the Government of the Republic of Lithuania dated June 29, 1999 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and capital”
Luxembourg	Agreement between the Russian Federation and the Grand Duchy of Luxembourg of June 28, 1993 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and property”
Macedonia	Agreement between the Government of the Russian Federation and the Government of the Republic of Macedonia of October 21, 1997 “On the avoidance of double taxation in relation to taxes on income and property”
Malaysia	Agreement between the Government of the USSR and the Government of Malaysia of July 31, 1987 “On the avoidance of double taxation with respect to taxes on income”
Mali	Convention between the Government of the Russian Federation and the Government of the Republic of Mali of June 25, 1996 “On the avoidance of double taxation and the establishment of rules for mutual assistance in relation to taxes on income and property”
Morocco	Agreement between the Government of the Russian Federation and the Government of the Kingdom of Morocco dated September 4, 1997 “On the avoidance of double taxation in relation to taxes on income and property”
Mexico	Agreement between the Government of the Russian Federation and the Government of the United Mexican States of June 7, 2004 “On the avoidance of double taxation with respect to income taxes”
Moldova	Agreement between the Government of the Russian Federation and the Government of the Republic of Moldova of April 12, 1996 “On the avoidance of double taxation of income and property and the prevention of tax evasion”
Mongolia	Agreement between the Government of the Russian Federation and the Government of Mongolia dated April 5, 1995 “On the avoidance of double taxation in relation to taxes on income and property”
Namibia	Convention between the Government of the Russian Federation and the Government of the Republic of Namibia of March 31, 1998 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income”
Netherlands	Agreement between the Government of the Russian Federation and the Government of the Kingdom of the Netherlands of December 16, 1996 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and property”
New Zealand	Agreement between the Government of the Russian Federation and the Government of New Zealand of September 5, 2000 “On the avoidance of double taxation and the prevention of tax evasion in relation to income taxes”
Norway	Convention between the Russian Federation and the Kingdom of Norway of March 26, 1996 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital”
Poland	Agreement between the Government of the Russian Federation and the Government of the Republic of Poland of May 22, 1992 “On the avoidance of double taxation of income and property”
Portugal	Convention between the Government of the Russian Federation and the Government of the Portuguese Republic of May 29, 2000 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income”
Romania	Convention between the Government of the Russian Federation and the Government of Romania of September 27, 1993 “On the avoidance of double taxation with respect to taxes on income and property”
Saudi Arabia	Convention between the Government of the Russian Federation and the Government of the Kingdom of Saudi Arabia of February 11, 2007 "On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital"
Serbia; Montenegro	Convention between the Government of the Russian Federation and the Federal Government of the Federal Republic of Yugoslavia of October 12, 1995 “On the avoidance of double taxation with respect to taxes on income and property”
Singapore	Agreement between the Government of the Russian Federation and the Government of the Republic of Singapore dated September 9, 2002 “On the avoidance of double taxation and the prevention of tax evasion in relation to income taxes”
Syria	Agreement between the Government of the Russian Federation and the Government of the Syrian Arab Republic of September 17, 2000 “On the avoidance of double taxation in relation to income taxes”
Slovakia	Agreement between the Government of the Russian Federation and the Government of the Slovak Republic of June 24, 1994 “On the avoidance of double taxation of income and property”
Slovenia	Convention between the Government of the Russian Federation and the Government of the Republic of Slovenia of September 29, 1995 “On the avoidance of double taxation with respect to taxes on income and property”
USA	Treaty between the Russian Federation and the United States of June 17, 1992 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income and capital”
Tajikistan	Agreement between the Government of the Russian Federation and the Government of the Republic of Tajikistan dated March 31, 1997 “On the avoidance of double taxation and the prevention of tax evasion on income and capital”
Thailand	Convention between the Government of the Russian Federation and the Government of the Kingdom of Thailand of September 23, 1999 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income”
Turkmenistan	Agreement between the Government of the Russian Federation and the Government of Turkmenistan dated January 14, 1998 “On the elimination of double taxation in relation to taxes on income and property”
Türkiye	Agreement between the Government of the Russian Federation and the Government of the Republic of Turkey dated December 15, 1997 “On the avoidance of double taxation with respect to income taxes”
Uzbekistan	Agreement between the Government of the Russian Federation and the Government of the Republic of Uzbekistan dated March 2, 1994 “On the avoidance of double taxation of income and property”
Ukraine	Agreement between the Government of the Russian Federation and the Government of Ukraine of February 8, 1995 “On the avoidance of double taxation of income and property and the prevention of tax evasion”
Philippines	Convention between the Government of the Russian Federation and the Government of the Republic of the Philippines of April 26, 1995 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income”
Finland	Agreement between the Government of the Russian Federation and the Government of the Finnish Republic of May 4, 1996 (as amended on April 14, 2000) “On the avoidance of double taxation with respect to income taxes”
France	Convention between the Government of the Russian Federation and the Government of the French Republic of November 26, 1996 “On the avoidance of double taxation and the prevention of tax evasion and violation of tax legislation in relation to taxes on income and property”
Croatia	Agreement between the Government of the Russian Federation and the Government of the Republic of Croatia of October 2, 1995 “On the avoidance of double taxation in relation to taxes on income and property”
Czech	Convention between the Government of the Russian Federation and the Government of the Czech Republic of November 17, 1995 “On the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital”
Chile	Convention between the Government of the Russian Federation and the Government of the Republic of Chile of November 19, 2004 on the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income and capital
Switzerland	Agreement between the Russian Federation and the Swiss Confederation of November 15, 1995 “On the avoidance of double taxation with respect to taxes on income and capital”
Sweden	Convention between the Government of the Russian Federation and the Government of the Kingdom of Sweden of June 15, 1993 “On the avoidance of double taxation with respect to taxes on income”
Sri Lanka	Agreement between the Government of the Russian Federation and the Government of the Democratic Socialist Republic of Sri Lanka dated March 2, 1999 “On the avoidance of double taxation and the prevention of tax evasion in relation to income taxes”
South Africa	Agreement between the Government of the Russian Federation and the Government of the Republic of South Africa dated November 27, 1995 “On the avoidance of double taxation and the prevention of tax evasion in relation to taxes on income”
Japan	Convention between the Government of the USSR and the Government of Japan of January 18, 1986 “On the avoidance of double taxation with respect to taxes on income”