russia - pkf · 2016-11-07 · capital gains are treated as ordinary business income and subject to...

2016/17

Russia

PKF Worldwide Tax Guide 2016/17 1

FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are there double tax treaties in place? How will foreign source income be taxed? Since 1994, the PKF network of independent member firms, administered by PKF International Limited, has produced the PKF Worldwide Tax Guide (WWTG) to provide international businesses with the answers to these key tax questions. As you will appreciate, the production of the WWTG is a huge team effort and we would like to thank all tax experts within PKF member firms who gave up their time to contribute the vital information on their country's taxes that forms the heart of this publication. The PKF Worldwide Tax Guide 2016/17 (WWTG) is an annual publication that provides an overview of the taxation and business regulation regimes of the world's most significant trading countries. In compiling this publication, member firms of the PKF network have based their summaries on information current on 30 April 2016, while also noting imminent changes where necessary. On a country-by-country basis, each summary such as this one, addresses the major taxes applicable to business; how taxable income is determined; sundry other related taxation and business issues; and the country's personal tax regime. The final section of each country summary sets out the Double Tax Treaty and Non-Treaty rates of tax withholding relating to the payment of dividends, interest, royalties and other related payments. While the WWTG should not to be regarded as offering a complete explanation of the taxation issues in each country, we hope readers will use the publication as their first point of reference and then use the services of their local PKF member firm to provide specific information and advice. Services provided by member firms include: Assurance & Advisory;

Financial Planning / Wealth Management;

Corporate Finance;

Management Consultancy;

IT Consultancy;

Insolvency - Corporate and Personal;

Taxation;

Forensic Accounting; and,

Hotel Consultancy. In addition to the printed version of the WWTG, individual country taxation guides such as this are available in PDF format which can be downloaded from the PKF website at www.pkf.com

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IMPORTANT DISCLAIMER This publication should not be regarded as offering a complete explanation of the taxation matters that are contained within this publication. This publication has been sold or distributed on the express terms and understanding that the publishers and the authors are not responsible for the results of any actions which are undertaken on the basis of the information which is contained within this publication, nor for any error in, or omission from, this publication. The publishers and the authors expressly disclaim all and any liability and responsibility to any person, entity or corporation who acts or fails to act as a consequence of any reliance upon the whole or any part of the contents of this publication. Accordingly no person, entity or corporation should act or rely upon any matter or information as contained or implied within this publication without first obtaining advice from an appropriately qualified professional person or firm of advisors, and ensuring that such advice specifically relates to their particular circumstances. PKF International Limited (PKFI) administers a family of legally independent firms. Neither PKFI nor the member firms of the network generally accept any responsibility or liability for the actions or inactions of any individual member or correspondent firm or firms. PKF INTERNATIONAL LIMITED JUNE 2016 © PKF INTERNATIONAL LIMITED All RIGHTS RESERVED USE APPROVED WITH ATTRIBUTION

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STRUCTURE OF COUNTRY DESCRIPTIONS A. TAXES PAYABLE

CORPORATE INCOME TAX TAX PERIOD TAX RATES CONTROLLED FOREIGN COMPANIES AND CONTROLLING ENTITIES CAPITAL GAINS TAX BRANCH PROFITS TAX VALUE ADDED TAX (VAT) OTHER FEDERAL TAXES SPECIAL SYSTEM OF TAXATION REGIONAL TAXES LOCAL TAXES INDIVIDUAL PROPERTY TAX

B. DETERMINATION OF TAXABLE INCOME

DEPRECIATION STOCK / INVENTORY CAPITAL GAINS AND LOSSES DIVIDENDS INTEREST DEDUCTIONS LOSSES FOREIGN SOURCED INCOME

C. FOREIGN TAX RELIEF D. CORPORATE GROUPS E. RELATED PARTY TRANSACTIONS F. WITHHOLDING TAXES G. EXCHANGE CONTROL H. PERSONAL TAX

INSURANCE CONTRIBUTIONS I. TREATY AND NON-TREATY WITHHOLDING TAX RATES

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MEMBER FIRM City Name Contact information Kazan Sergey Nikiforov +7 843 555 64 94 [email protected] St. Petersburg Tatiana Gavrilova +7 812 600 91 03 [email protected] BASIC FACTS Full name: Russian Federation Capital: Moscow Main language: Russian Population: 143.90 million (2014 estimate)(not including Republic of Crimea and Sevastopol) Major religion: Christianity Monetary unit: Russian Ruble (RUB) Internet domain: .ru Int. dialling code: +7 KEY TAX POINTS The taxation system in the Russian Federation is based on a combination of the federal, regional,

and local taxes and levies. Federal taxes and levies include: Value Added Tax (VAT), Excise Duties, Individual Income Tax,

Corporate Income Tax, Mineral Extraction Tax, Water Tax, State Duty, and fees for using of wildlife resources and aquatic biological resources.

Regional taxes include: Corporate Property Tax, Gambling Tax and Transport Tax. Local taxes and levies include Land Tax, Individual Property Tax and Sales Tax. The tax period is a calendar year or other period of time in relation to specific taxes at the end of

which the tax base is calculated and the tax payable is assessed. The tax period may cover more than one reporting periods.

The standardcompany tax rate is currently 20% and this is also the rate of the profit tax paid by foreign enterprises deriving income which is not connected with carrying out their business activities through a permanent establishment.

Capital gains are treated as ordinary business income and subject to profits tax. Value Added Tax (VAT) is levied at a standard rate of 18% and applies to the sale of goods,

worksand services in Russia and the import of goods into the Russian Federation. Tax rate for tax base defined by taxpayers-controlling parties based on profit of the controlled

foreign companies is 20%. Thin capitalisation rules apply to restrict the deduction of interest where it is paid to a foreign

enterprise that holds more than 20% of the share capital of a Russian entity. Transactions between related parties are subject to transfer pricing rules and a company has to

support the arm’s length nature of its transactions. It is possible to enter into advance pricing agreements with the tax authorities, which are typically for a three year period.

Foreign legal entities deriving profits in connection with activities within Russia may be subject to withholding taxes on dividends, interest and royalties. The withholding tax rate 30% is applied in respect of income from securities issued by Russian companies.

• A special tax regime has been established to taxpayers registered within the Special Economic Zones

Individuals are considered to be resident if they spend more than 183 days in Russia during a continuous 12-month period. Residents are subject to income tax on their worldwide income and non-residents on their Russian-sourced income only.

Registration (deregistration) with the tax authorities of the foreign company at its place of business in the territory of the Russian Federation: - Through an accredited branch or representative office based on the data contained in the

state register of accredited branches and representative offices of foreign legal entities; - Through other separate subdivisions based on the application for the registration

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(deregistration) of such company unless otherwise provided by Clause 3 of this article. In case several separate subdivisions of a company are located in the same municipality, the

federal cities Moscow, St. Petersburg and Sevastopol in the territories under the jurisdiction of different tax authorities, the company may be registered with the tax authorities at the location of one of its separate subdivisions at the discretion of the company. The company shall specify the tax authorities for registration in the notification submitted (sent) by the Russian company to the tax authorities at the place of its business (in case of a foreign company- to the tax authorities chosen at the discretion of the company).

The personal income tax rate for residents and foreign highly skilled specialists is 13%. A special 35% rate is applied to some kinds of income, e.g. the cost of any prizes and wins, voluntary insurance proceeds, interest on certain bank deposits and deposits on foreign currency. A 13% rate is applied to income in the form of dividends received from shareholdings. All personal income of non-residents, excluding dividends, is taxed at the rate of 30%.

Russia has concluded 80 Double Taxation Treaties. A. TAXES PAYABLE CORPORATE INCOME TAX Corporate taxpayers include: • Russian companies; • Foreign companies which operate in the Russian Federation through permanent representative

offices and (or) receiving income from sources in the Russian Federation; • Foreign companies recognized as tax residents of the Russian Federation are considered as

Russian companies. For the purpose of the Tax Code, the following organizations are recognized as tax residents of the Russian Federation: 1) Russian companies; 2) Foreign companies recognized as tax residents of the Russian Federation in accordance with the

international tax treaty - for the purpose of applying this international treaty; 3) Foreign companies actually managed in the Russian Federation unless otherwise is provided by

the international tax treaty. Companies which are responsible participants of the consolidated group of taxpayers are recognized as income taxpayers of such consolidated group of taxpayers. TAX PERIOD The tax period is one calendar year. The reporting periods for tax purposes are the first quarter, a half-year, and nine months of a calendar year. With the exception of foreign legal entities, enterprises are obliged to make monthly advance payments of their quarterly liabilities. Advance payments are due not later than the 28th day of the corresponding month. TAX RATES The standard rate of tax is currently of 20% of which of 2% of is normally paid to the federal budget and 18% - to the budgets of constituent entities of the Russian Federation. The tax rate of the tax payable to the budgets of constituent entities of the Russian Federation may be lowered by the laws of constituent entities of the Russian Federation for specific categories of taxpayers. Yet, the specified tax rate may not be lower than 13.5% unless otherwise is established by the Tax Code (in particular, special tax rates for taxpayers which are participants of regional investment projects are established). Foreign enterprises deriving income which is not connected with carrying out their business activities through a permanent establishment pay profit tax at the rate of 20%. A rate of 10% applies to non-residents on income from the use, maintenance or rent of charter ships, aircraft and other moving vehicles or containers (including trailers and ancillary equipment required for traffic) in connection with international traffic. A rate of 15% applies to non-residents receiving dividends. Domestic enterprises have the option to pay tax monthly based on their actual profits. Payments are due no later than the

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28th day of the following month. Foreign enterprises carrying out their business activities through permanent establishments make quarterly advance payments. In general, income tax returns must be filed no later than 28 March following the tax year. The following allowances are deducted from the taxable base: • Profits received as payments to the charter capital; • The costs of maintaining certain social facilities; • Profits received as special-purpose financing in the forms of:

(a) Foreign financing of capital investments; (b) Grants for the benefit of culture, sports, recreation, scientific research and approved research

foundations; • Assets received by Russian enterprises free of charge for the purposes of increasing net assets

or from enterprises which hold more than 50% of the share capital of the recipient. In the latter case, the assets should not be distributed to a third person within a year of the original transfer.

CONTROLLED FOREIGN COMPANIES AND CONTROLLING ENTITIES A foreign company is recognized as a controlled foreign company if it meets the following conditions: 1) The company is not recognized as a tax resident of the Russian Federation; 2) The company’s controlling parties are companies and (or) individuals recognized as tax residents

of the Russian Federation. A controlled foreign company is also a foreign unincorporated entity which is controlled by companies and (or) individuals recognized as tax residents of the Russian Federation. Profit (loss) of a controlled foreign company is the profit (loss) of such company before taxation as per its annual financial statements prepared in accordance with the internal regulations of such company if, according to the internal regulations, its financial statements are subject to statutory audit; provided that the permanent location of the controlled foreign company is the foreign country with which the Russian Federation signed an international tax treaty. In other cases, profit (loss) of a controlled foreign company is the profit (loss) of such company determined under the regulations established by the Tax Code of the Russian Federation. Profit (loss) of each controlled foreign company shall be documented in its financial statements prepared in accordance with the internal regulations of such company for the corresponding period (periods) accompanied by its financial statements and tax returns. Tax rate for tax base defined by taxpayers-controlling parties based on profit of the controlled foreign companies is 20%. Profit of a controlled foreign company is exempt from taxation if such company meets at least one of the nine conditions provided by the Tax Code of the Russian Federation. CAPITAL GAINS TAX Capital gains are treated as ordinary business income and are therefore subject to profits tax according to the general rule. BRANCH PROFITS TAX There is no special branch profits tax in Russia. VALUE ADDED TAX (VAT) VAT is levied on the sale of goods and services in Russia and the import of goods into the Russian Federation. The taxable base is the sales price. The standard rate of VAT is 18%. Some supplies of basic foodstuffs and children's clothing and footwear are taxed at a reduced rate of 10%. Some imported medicines, medical and technological equipment (including components and spare parts) and scientific research are exempt from VAT. Other exemptions include cultural, scientific and educational services, as well as services rendered by attorneys. The tax period for VAT is per quarter.

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OTHER FEDERAL TAXES State Duty is paid by enterprises and individuals if they apply to public and local authorities, other bodies, or to officials who are entitled to commit legal actions. Excise Duties are levied on some goods such as alcohol, beer, cigarettes, cars and petrol. A mineral resources recovery tax applies to the cost of minerals extracted by a taxpayer company. Companies and individuals exercising water consumption for special purposes are subject to water tax. The tax rate is fixed and depends on the water body used. SPECIAL SYSTEM OF TAXATION Local authorities may determine an alternative income tax for certain small business activities such as personal services and retail sales. The tax is paid instead of profit tax, VAT (except on the import of the goods into the Russian Federation) and property tax. In this case, taxpayers calculate 'common tax' at the rate of 15% based on standard income and determined by the local legislative body. In some cases, a simplified system of taxation may be applied as an alternative to common tax. Taxpayers whose income does not exceed RUR 45m after the end of the ninth month of the tax year (excluding VAT) have a right to use this system of taxation during the following year (except for banks, enterprises with affiliated branches etc.). These enterprises do not pay profit tax, VAT (except on the importation of the goods to the Russian Federation) and property tax. Only one tax is levied, as with 'common tax'. The tax payer can choose the taxable base for this tax - either gross income for the 6% rate or income minus expenses for the 15% tax rate. REGIONAL TAXES Resident enterprises and foreign companies that own property within the territory of the Russian Federation are liable to property tax. The rate is set by the regional authorities but cannot exceed 2.2%. The taxable base is the average aggregate annual depreciated value of fixed assets on the balance sheet of the resident company or permanent establishment concerned. Foreign companies which do not have a permanent establishment in Russia and which own only movable property are not subject to Russian Property Tax. The owners of transport facilities (cars, motorcycles, buses etc.) pay transport tax. This tax is imposed by territorial divisions of the Russian Federation (republics, regions and provinces). The tax rate depends on the technical specification of the vehicles owned. Taxpayers must pay the tax according to a contributory scheme determined by legislative bodies of regions of the Russian Federation. Companies operating gambling establishments are subject to a tax on the gambling industry. The tax rates are fixed and are not related to profit. LOCAL TAXES Local authorities can define certain tax rules but cannot impose taxes not stipulated by the federal tax law. Land tax is payable at a rate of 0.3% on agricultural and residential land and 1.5% on other types of land. The taxable base is the value of land as stated in the state land register as at 1 January of the relevant tax year. INDIVIDUAL PROPERTY TAX Taxable items include: 1) Residential building; 2) Residential unit (apartment, room); 3) Garage, parking space; 4) Real estate complex; 5) Construction in progress; 6) Other buildings, constructions, structures or premises.

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The tax is established by the Tax Code and regulations issued by the representative bodies of municipalities. The representative bodies of municipalities (legislative (representative) bodies of the federal cities Moscow, St. Petersburg and Sevastopol) establish tax rates in the limits set by the Tax Code (as a percentage of a cadastral or inventory value of property). B. DETERMINATION OF TAXABLE INCOME Taxable profits are calculated by ascertaining assessable income and then deducting all allowable expenses. In general, companies may deduct all necessary expenses paid or accrued during the year in the course of a business. DEPRECIATION Only the straight-line method may be used to calculate depreciation of certain groups of fixed assets such as buildings, construction and transfer mechanisms. Depreciation of other fixed assets should be calculated by a taxpayer using either the straight-line method or the accelerated method, depending on which method they prefer. Depreciation is calculated on a monthly basis and must be taken whether or not the company makes profits in the period. STOCK/INVENTORY Under accounting law, stock is valued at its purchase cost. The profits tax law contains no provision concerning valuation of stock. The cost of materials transferred to production may be determined by the following valuation methods: average cost, cost of item, FIFO or LIFO. CAPITAL GAINS AND LOSSES As discussed above, capital gains and losses are subject to profit tax at regular corporate rates. DIVIDENDS Dividends paid by Russian companies are subject to a final withholding tax whether they are paid to resident or non-resident recipients. Dividends received by resident companies are subject to a 0% withholding tax rate if: • The recipient holds at least 50% of the capital of the payer; and, • The participation has been held continuously for the past 365 calendar days. The tax rate for dividends paid to a non-resident company or individual is 15%. The tax rate for dividends paid to a resident individual is 13%. The tax rate for dividends paid to a resident company is 13%. INTEREST DEDUCTIONS Thin capitalisation rules apply where interest is paid to a foreign enterprise that holds more than 20% of the share capital of a Russian entity. If the debt exceeds equity by more than 3:1 (for bank companies, more than 12.5:1), the amount of interest deductible by the Russian entity is restricted. The difference between the real amount of interest and that calculated under Russian Tax legislation is treated as a dividend paid out by the Russian entity to its foreign shareholder and is subject to 15%withholding tax base. LOSSES Taxpayers who suffered loss (losses) in the previous tax period(s) have the right to reduce the tax base for the current reporting (tax) period by the total amount of loss or by the part of such amount (to carry over the loss). A taxpayer has the right to carry over a loss within ten years following the tax period in which the loss was incurred.

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FOREIGN SOURCED INCOME Foreign sourced income and gains are subject to profit tax at the regular rate except dividends. C. FOREIGN TAX RELIEF The Russian tax law provides a tax credit for foreign taxes paid on foreign sourced profits or revenues subject to a limit which is equal to the maximum amount of Russian tax due on the same profits or revenues. Any excess foreign tax credits may not be transferred to future or previous periods. No credit is granted for underlying corporate income tax on dividends. D. CORPORATE GROUPS The concept of fiscal unity is applied in Russia from 1 January 2012. Banks, insurance companies and some other types of entities are excluded. E. RELATED PARTY TRANSACTIONS Inter-company pricing between affiliated companies must be carried out on an arm's length basis or the income of both companies is adjusted for tax purposes. Taxpayers are obliged to provide the tax authorities with documentation containing data about the activities of the taxpayer and other parties to the transaction. This includes a list of the parties to the transaction, description of the transaction, terms of the transaction, methods of pricing, terms and conditions of payments etc., functions of the parties of the transaction (during functional analysis), information about accepted risks considered by the taxpayer when concluding the transaction and so on. The largest of taxpayers can conclude advance agreements with the tax authorities regarding the determination of prices and application of pricing methods in controlled transactions. Such agreements shall be valid for not more than three years. F. WITHHOLDING TAXES Foreign legal entities obtaining profits in connection with activities within Russia may be subject to withholding taxes on dividends, interest and royalties. The withholding tax rate 30% is applied in respect of income from securities issued by Russian companies, the rights to which are recorded in the custody account of a foreign nominee holder, foreign authorised holder and (or) foreign depository programs, paid to persons for which information was not provided to the tax agent. G. EXCHANGE CONTROL Generally, hard currency transactions between Russian residents and non-residents are executed without any limitation. However, certain transactions are subject to state regulations and restrictions. Hard currency transactions between residents are forbidden with certain exceptions. Hard currency transactions between non-residents may be carried out without limitations. H. PERSONAL TAX Personal income tax is levied on resident and non-resident individuals, whether or not they are citizens of the Russian Federation. Individuals are considered to be resident if they spend more than 183 days in Russia during a continuous 12-month period. Residents are subject to income tax on their worldwide income and non-residents on their Russian-sourced income only. The personal income tax rate for residents and foreign highly skilled specialists is 13%. A special 35% rate is applied to some kinds of income, e.g. the cost of any prizes and wins, voluntary insurance proceeds, interest on certain bank deposits and deposits on foreign currency. A 13% rate is applied to income in the form of

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dividends received by residents and rate of 15% is applied if the dividend income is received by non-residents. All personal income of non-residents, excluding dividends, is taxed at the rate of 30%. For dividends a tax rate 15% is applied. The tax rate of 30% is applied in respect of income from securities issued by Russian companies, the rights to which are recorded in the custody account of a foreign nominee holder, foreign authorised holder and/or foreign depository programs, paid to persons for which information was not provided to the tax agent. The following types of income are exempt from tax: • Welfare payments, except for temporary disability, and compensations paid out incompliance

with legislation currently in force; • All kinds of compensatory payments, prescribed by legislation, concerned with discharging of

labour duties; • Alimonies; • Grants for the purpose of science, education, culture and art, given by international and foreign

organisations; • Scholarships and some others. In determining the taxable base, individuals are entitled to the following statutory deductions: • Property-related allowance; • Social allowance; • Professional deductions; and, • Standard allowance. The conditions for exempting income derived from the sale of real estate from taxation: • Full exemption - for real estate that has been held for over five years; • In a limited number of cases, the Personal income tax exemption can be applied after three

years of ownership. According to the tax legislation: • Gifts received from individuals are included in the list of items of income that are exempt from

income tax. Gifts of immovable property, vehicles and shares are taxable unless these items are received from close relatives;

• Gifts received from individual entrepreneurs and legal entities are exempt up to RUR 4,000 in a calendar year. The excess is taxable at a rate of 13% for residents and 30% for non-residents;

• Inherited property is exempt from tax. INSURANCE CONTRIBUTIONS Insurance contributions taxpayers are: 1) Individuals who pay benefits and provide other remuneration to physical persons:

а) Companies; b) Individual entrepreneurs; c) Individuals not recognized as individual entrepreneurs;

2) Individuals who do not pay benefits or provide other remuneration to physical persons: Individual entrepreneurs, lawyers and notaries engaged in private practice, and other persons engaged in private practice.

The rates of insurance contributions for 2015-2017 for taxpayers who pay benefits and provide other remuneration to physical persons: 1) Pension Fund of the Russian Federation:

• 22.0% within the established limit of insurance contribution base for compulsory pension insurance;

• 10.0%over the established limit of insurance contribution base for compulsory pension insurance;

2) Social Insurance Fund of the Russian Federation–2.9% within the established limit of insurance contribution base for compulsory social insurance against temporary disability and in respect of maternity benefit;

3) Federal Compulsory Medical Insurance Fund – 5.1%. In case of benefits and other remuneration payable to foreign citizens and stateless persons residing temporarily in the territory of the Russian Federation (except for highly qualified specialists), the rate of

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insurance contributions to the Social Insurance Fund of the Russian Federation is 1.8%. Taxpayers of insurance contributions who do not pay benefits or provide other remuneration to physical persons shall pay the corresponding insurance contributions to the Pension Fund of the Russian Federation and the Federal Compulsory Health Insurance Fund at the rates established by the law. Special rates are established for certain groups of employers and professions. I. TREATY AND NON-TREATY WITHHOLDING TAX RATES

The table below shows the withholding tax rates on dividends, interest and royalties under tax treaties concluded by the USSR and the Russian Federation. The Russian Federation has announced that it will honour the international agreements existing between the USSR and other countries. The table is for general guidance only. The relevant treaty should be consulted to confirm the rates applicable in each case.

Dividends (%)

Interest (%)

Royalties (%)

Non-treaty countries: 15 20 20

Treaty countries:

Albania 10 10 10

Algeria 5/15 15 15

Argentina 10/15 15 15

Armenia 5/10 10 0

Australia 5/15 10 10

Austria 5/15 0 0

Azerbaijan 10 10 10

Belarus 15 10 10

Belgium 10 10 0

Brazil 10/15 15 15

Bulgaria 15 15 15

Canada 10/15 0/10 0/10

Chile 5/10 15 5/10

China 10 10 10

Croatia 5/10 10 10

Cuba 5/15 10/0 5/0

Cyprus 5/10 0 0

Czech Republic 10 0 10

Denmark 10 0 0

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Dividends (%)

Interest (%)

Royalties (%)

Egypt 10 15 15

Finland 5/12 0 0

France 5/10/15 0 0

Germany 5/15 0 0

Greece 5/10 7 7

Hungary 10 0 0

India 10 10 10

Indonesia 15 15 15

Iran 5/10 7,5 5

Ireland 10 0 0

Iceland 5/15 0 0

Israel 10 10 10

Italy 5/10 10 0

Japan 15 10 0/10

Kazakhstan 10 10 10

Korea, Democratic Republic of, 10 0 0

Korea, Republic of 5/10 0 5

Kuwait 5 0 10

Kyrgyzstan 10 10 10

Latvia 5/10 5/10 5

Lebanon 10 5 5

Lithuania 5/10 10 5/10

Luxembourg 5/15 0 0

Macedonia 10 10 10

Malaysia –1/152 0/15 10/15

Mali 10/15 15 0

Mexico 10 10 10

Morocco 5/10 10 10

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Dividends (%)

Interest (%)

Royalties (%)

Moldova 10 0 10

Mongolia 10 10 –1

Montenegro 15/5 10 10

Namibia 5/10 10 5

Netherlands 5/15 0 0

New Zealand 15 10 10

Norway 10 10 0

Philippines 15 15 15

Poland 10 10 10

Portugal 10/15 10 10

Qatar 5 5 0

Romania 15 15 10

Saudi Arabia 5 5 10

Serbia 15/5 10 10

Singapore 5/10 7.5 7.5

Slovak Republic 10 0 10

Slovenia 10 10 10

South Africa 10/15 10 0

Spain 5/10/15 5 5

Sri Lanka 10/15 10 10

Sweden 5/15 0 0

Switzerland 5/15 0 0

Syria 15 10 13.5/18

Tajikistan 5/10 10 0

Thailand 15 10 15

Turkey 10 10 10

Turkmenistan 10 5 5

Ukraine 5/15 10 10

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Dividends (%)

Interest (%)

Royalties (%)

United Kingdom 10 0 0

United States 5/10 0 0

Uzbekistan 10 10 0

Venezuela 10/15 5/10 10/15

Vietnam 10/15 10 15

NOTES: 1 There is no reduction under the treaty - the domestic rate applies. 2 The 15% rate applies to Joint Ventures. The domestic rate applies in other cases.

russia - pkf · 2016-11-07 · capital gains are treated as ordinary business income and subject to...

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