Decree No. 585 · 8 August 2023

Suspension of double tax treaties with 38 states

Russia stopped applying the key articles of its tax treaties with 38 unfriendly states — reduced withholding rates and non-discrimination among them.

What it does

Decree No. 585 instructed the Government and the Ministry of Foreign Affairs to suspend the application of the core provisions of Russia's double tax treaties with 38 states that have taken unfriendly actions. The suspension covers in particular the articles on dividends, interest, royalties and capital gains, and the non-discrimination clause, so Russian domestic withholding rates apply in full: 15% on dividends and 20% on interest and royalties paid to foreign companies. Notes to the treaty partners were sent on the same day. The Russian list differs from the general “unfriendly” list in Directive No. 430-r.

Germany responded by suspending its 1996 treaty with Russia in full from 1 January 2027 (notification of 30 June 2026). The treaty guide covers the consequences.

Status, October 2026

In force, “until further notice”.

Guides that discuss it

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