The Russian Double Tax Treaty with Cyprus
The 1998 treaty for the avoidance of double taxation between Cyprus and Russia was completed with a Protocol to the Agreement for the avoidance of double taxation between Russia and Cyprus, ratified by the Russian “Duma” on 15 February 15, 2012.
The Protocol is expected to be signed, as last step in order to be enforceable, by the Russian President, supposedly until the end of 2012 in order to have effect starting with January 1, 2013 for some provisions and others from 2017. Upon its ratification, Cyprus will be removed from the Russian “black list” of offshore jurisdictions.
This will allow Russian companies to qualify for the Russian dividend participation exemption if dividends are paid by Russian companies to Cyprus Holdings, thus facilitating the investments into Russia as well.