Russia terminated the DTT with the Netherlands

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From January 1st, 2022, the tax treaty with the Netherlands expires. The agreements of states on exemption from taxation of certain types of income, on the application of reduced rates of withholding tax, on the application of special rules for the elimination of double taxation will be terminated.

Parameters for increasing the tax burden:

• tax on dividends paid from Russia will increase from 5% to 15%,

• tax on royalties, rent payments, lease payments made from Russia will increase from 0% to 20%,

• tax on income from the sale of participation interests, shares of companies, more than 50% of whose assets are represented by Russian real estate, paid from Russia, will increase from 0% to 20%.

As a complication of tax administration:

• for the purposes of a CFC – the need to prepare an auditor’s report on financial statements (if the CFC’s profit is calculated based on financial statements).