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
Decree No. 585 and the suspended tax treaties: withholding on dividends, interest and royalties in 2026
Which 38 treaties Russia suspended in 2023, which partners have since suspended or terminated on their side (Germany from 1 January 2027), and what a Russian payer withholds today.
Liquidating a Russian subsidiary with an unfriendly shareholder: permits, payouts and timing
Winding up instead of selling — whether the liquidation decision needs a permit, how the liquidation proceeds reach the parent (they mostly do not), the tax on the way out and a realistic timetable.