Page 81 - RusRPTSept23

DTTs are needed to free from the double tax burden people or companies that are tax residents in one country (in the general case, this requires spending more than 183 days in the country), but receive income in other countries. The agreements allow them to pay tax in only one of the countries (usually the one in which it is lower) or in two, but at preferential rates.
In March, the Ministry of Finance and the Foreign Ministry proposed to suspend the DTT with "unfriendly" countries as a response to the inclusion of Russia in the black list of EU tax jurisdictions. Putin's decree implements these proposals, but in a softened form. The agreements themselves are not broken and do not cease to operate completely - only a part of their articles (albeit a large one) is suspended. The list of articles that will be suspended is right in the decree, and for verification, you can use the standard DTT with Germany.
The main articles for individuals remain unchanged - on determining tax residency and methods for eliminating double taxation. At the same time, the operation of all articles that determine the taxation regimes for certain incomes (for example, from the sale or lease of real estate, one of the most important for individuals), is suspended. Most lawyers interviewed by RBC, Forbes and Frank Media agree that this means that individuals can continue to credit taxes paid in one country in another - that is, nothing will change for them. The Ministry of Finance promised citizens back in June that the suspension of agreements would not affect individuals.
At the same time, lawyers note the risk of denunciation of agreements in the future - both by the second countries as a response to Russian actions, and by Russia itself in the event of further escalation.
For businesses (both foreign and Russian, registered in foreign jurisdictions), there is no good news. The suspension of articles that fell into Putin's decree means the abolition of reduced tax rates for all income - payments abroad of dividends, interest on debt obligations, royalties, income from rental and sale of real estate, sales of shares of companies, entrepreneurial activities. True, some of these incomes were already impossible to withdraw from Russia - for example, dividends (only 10mn rubles a month can be paid abroad, everything else can only be paid to a Russian account of type "C").
RUSSIA Country Report September 2023 www.intellinews.com