2015 /16

Russia

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 2015/16 (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 1 January 2015, 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

PKF Worldwide Tax Guide 2015/16

Russia

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 is a family of legally independent member firms administered by PKF International
Limited (PKFI). Neither PKFI nor the member firms of the network generally accept any responsibility
or liability for the actions or inactions on the part of any individual member firm or firms.

PKF INTERNATIONAL LIMITED

JUNE 2015
PKF INTERNATIONAL LIMITED
All RIGHTS RESERVED
USE APPROVED WITH ATTRIBUTION

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STRUCTURE OF COUNTRY DESCRIPTIONS

A. TAXES PAYABLE
CORPORATE 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
For further advice or information please contact:
City

Name

Contact information

Kazan

Sergey Nikiforov

+7 843 555 64 94
nikifomv@acg-pkf.ru

St. Petersburg

Tatiana Gavrilova

+7 812 600 91 03
audlt@mcd.spb.ru

BASIC FACTS
Full name:
Capital:
Main language:
Population:
Major religion:
Monetary unit:
Internet domain:
Int. dialling code:

Russian Federation
Moscow
Russian
143.90 million (2014 estimate) (not including Republic of Crimea and Sevastopol)
Christianity
Russian Ruble (RUB)
.ru
+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 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 standard company 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, works
and 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%.

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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 arms 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.

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
(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 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;

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Foreign companies recognized as tax residents of the Russian Federation are considered as
Russian companies.

For the purpose of this Code, the following organisations 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 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.
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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 companys 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. Until January 1,
2016, a party is recognized as the party controlling a company (including foreign unincorporated
entities) if such partys participation share in the company (for individuals - together with spouses
and minor children) is more than 50%.
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.

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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)

There is no sales tax in Russia. 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 equipment 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.

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.

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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.

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).

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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.

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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.

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.
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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 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 in compliance
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,

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Standard allowance.

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)

2)

Individuals who pay benefits and provide other remuneration to physical persons:
)

Companies;

b)

Individual entrepreneurs;

c)

Individuals not recognized as individual entrepreneurs;

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 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
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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
(%)

15

20

20

Albania

10

10

10

Algeria

5/15

15

15

Argentina

10/15

15

15

Armenia

5/10

10

Australia

5/15

10

10

Austria

5/15

Azerbaijan

10

10

10

Belarus

15

10

10

Belgium

10

10

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

Czech Republic

10

10

Denmark

10

Egypt

10

15

15

Finland

5/12

France

5/10/15

Germany

5/15

Greece

5/10

Hungary

10

India

10

10

10

Non-treaty countries:
Treaty countries:

Brazil

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Dividends
(%)

Interest
(%)

Royalties
(%)

15

15

15

5/10

7,5

Ireland

10

Iceland

5/15

Israel

10

10

10

Italy

5/10

10

Japan

15

10

0/10

Kazakhstan

10

10

10

Korea, Democratic Republic of,

10

5/10

Kuwait

10

Kyrgyzstan

10

10

10

5/10

5/10

Lebanon

10

Lithuania

5/10

10

5/10

Luxembourg

5/15

10

10

0/15

10/15

Indonesia
Iran

Korea, Republic of

Latvia

Macedonia

10
1

Malaysia

/15

Mali

10/15

15

10

10

10

Morocco

5/10

10

10

Moldova

10

10

Mongolia

10

10

Montenegro

15/5

10

10

Namibia

5/10

10

Netherlands

5/15

New Zealand

15

10

10

Norway

10

10

Philippines

15

15

15

Poland

10

10

10

10/15

10

10

Qatar

Romania

15

15

10

Saudi Arabia

10

Serbia

15/5

10

10

Singapore

5/10

7.5

7.5

Slovak Republic

10

10

Slovenia

10

10

10

10/15

10

5/10/15

Mexico

Portugal

South Africa
Spain
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Dividends
(%)

Interest
(%)

Royalties
(%)

Sri Lanka

10/15

10

10

Sweden

5/15

Switzerland

5/15

15

10

13.5/18

Tajikistan

5/10

10

Thailand

15

10

15

Turkey

10

10

10

Turkmenistan

10

5/15

10

10

10

5/10

Uzbekistan

10

10

Venezuela

10/15

5/10

10/15

Vietnam

10/15

10

15

Syria

Ukraine
United Kingdom
United States

NOTES:
1

There is no reduction under the treaty - the domestic rate applies.

The 15% rate applies to Joint Ventures. The domestic rate applies in other cases.

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