RussiaTax Guide

2013

PKF Worldwide Tax Guide 2013 I

Fore

wor

d

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. This handy reference guide provides clients and professional practitioners with comprehensive tax and business information for over 90 countries throughout the world.

As you will appreciate, the production of the WWTG is a huge team effort and I would like to thank all tax experts within PFK member firms who gave up their time to contribute the vital information on their country’s taxes that forms the heart of this publication.

I hope that the combination of the WWTG and assistance from your local PKF member firm will provide you with the advice you need to make the right decisions for your international business.

Richard SackinChairman, PKF International Tax CommitteeEisner Amper LLP richard.sackin@eisneramper.com

PKF Worldwide Tax Guide 2013II

Disclaimer

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 network 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 Worldwide Tax Guide 2013 III

Pref

ace

preface

The PKF Worldwide Tax Guide 2013 (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 2013, while also noting imminent changes where necessary.

On a country-by-country basis, each summary 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.

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

PKF INTERNATIONAL LIMITEDMAY 2013

©PKF INTERNATIONAL LIMITEDALL RIGHTS RESERVEDUSE APPROVED WITH ATTRIBUTION

PKF Worldwide Tax Guide 2013IV

Introduction

about pKf international limited

PKF International Limited (PKFI) administers the PKF network of legally independent member firms. There are around 300 member firms and correspondents in 440 locations in around 125 countries providing accounting and business advisory services. PKFI member firms employ around 2,270 partners and more than 22,000 staff.PKFI is the 11th largest global accountancy network and its member firms have $2.68 billion aggregate fee income (year end June 2012). The network is a member of the Forum of Firms, an organisation dedicated to consistent and high quality standards of financial reporting and auditing practices worldwide.

Services provided by member firms include:

Assurance & AdvisoryInsolvency – Corporate & PersonalFinancial Planning/Wealth managementTaxationCorporate FinanceForensic AccountingManagement ConsultancyHotel ConsultancyIT Consultancy

PKF member firms are organised into five geographical regions covering Africa; Latin America; Asia Pacific; Europe, the Middle East & India (EMEI); and North America & the Caribbean. Each region elects representatives to the board of PKF International Limited which administers the network. While the member firms remain separate and independent, international tax, corporate finance, professional standards, audit, hotel consultancy and business development committees work together to improve quality standards, develop initiatives and share knowledge and best practice cross the network.

Please visit www.pkf.com for more information.

PKF Worldwide Tax Guide 2013 V

Stru

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structure of country descriptions

a. taXes payable

FEDERAL TAXES AND LEVIES COMPANY TAX CAPITAL GAINS TAX BRANCH PROFITS TAX SALES TAX/VALUE ADDED TAX FRINGE BENEFITS TAX LOCAL TAXES OTHER TAXES

b. determination of taXable income

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

c. foreiGn taX relief

d. corporate Groups

e. related party transactions

f. witHHoldinG taX

G. eXcHanGe control

H. personal taX

i. treaty and non-treaty witHHoldinG taX rates

PKF Worldwide Tax Guide 2013VI

Time Zones

AAlgeria . . . . . . . . . . . . . . . . . . . .1 pmAngola . . . . . . . . . . . . . . . . . . . .1 pmArgentina . . . . . . . . . . . . . . . . . .9 amAustralia - Melbourne . . . . . . . . . . . . .10 pm Sydney . . . . . . . . . . . . . . .10 pm Adelaide . . . . . . . . . . . . 9.30 pm Perth . . . . . . . . . . . . . . . . . .8 pmAustria . . . . . . . . . . . . . . . . . . . .1 pm

BBahamas . . . . . . . . . . . . . . . . . . .7 amBahrain . . . . . . . . . . . . . . . . . . . .3 pmBelgium . . . . . . . . . . . . . . . . . . . .1 pmBelize . . . . . . . . . . . . . . . . . . . . .6 amBermuda . . . . . . . . . . . . . . . . . . .8 amBrazil. . . . . . . . . . . . . . . . . . . . . .7 amBritish Virgin Islands . . . . . . . . . . .8 am

CCanada - Toronto . . . . . . . . . . . . . . . .7 am Winnipeg . . . . . . . . . . . . . . .6 am Calgary . . . . . . . . . . . . . . . .5 am Vancouver . . . . . . . . . . . . . .4 amCayman Islands . . . . . . . . . . . . . .7 amChile . . . . . . . . . . . . . . . . . . . . . .8 amChina - Beijing . . . . . . . . . . . . . .10 pmColombia . . . . . . . . . . . . . . . . . . .7 amCyprus . . . . . . . . . . . . . . . . . . . .2 pmCzech Republic . . . . . . . . . . . . . .1 pm

DDenmark . . . . . . . . . . . . . . . . . . .1 pmDominican Republic . . . . . . . . . . .7 am

EEcuador . . . . . . . . . . . . . . . . . . . .7 amEgypt . . . . . . . . . . . . . . . . . . . . .2 pmEl Salvador . . . . . . . . . . . . . . . . .6 amEstonia . . . . . . . . . . . . . . . . . . . .2 pm

FFiji . . . . . . . . . . . . . . . . .12 midnightFinland . . . . . . . . . . . . . . . . . . . .2 pmFrance. . . . . . . . . . . . . . . . . . . . .1 pm

GGambia (The) . . . . . . . . . . . . . 12 noonGermany . . . . . . . . . . . . . . . . . . .1 pmGhana . . . . . . . . . . . . . . . . . . 12 noonGreece . . . . . . . . . . . . . . . . . . . .2 pmGrenada . . . . . . . . . . . . . . . . . . .8 amGuatemala . . . . . . . . . . . . . . . . . .6 am

Guernsey . . . . . . . . . . . . . . . . 12 noonGuyana . . . . . . . . . . . . . . . . . . . .7 am

HHong Kong . . . . . . . . . . . . . . . . .8 pmHungary . . . . . . . . . . . . . . . . . . .1 pm

IIndia . . . . . . . . . . . . . . . . . . . 5.30 pmIndonesia. . . . . . . . . . . . . . . . . . .7 pmIreland . . . . . . . . . . . . . . . . . . 12 noonIsle of Man . . . . . . . . . . . . . . 12 noonIsrael . . . . . . . . . . . . . . . . . . . . . .2 pmItaly . . . . . . . . . . . . . . . . . . . . . .1 pm

JJamaica . . . . . . . . . . . . . . . . . . .7 amJapan . . . . . . . . . . . . . . . . . . . . .9 pmJordan . . . . . . . . . . . . . . . . . . . .2 pm

KKenya . . . . . . . . . . . . . . . . . . . . .3 pm

LLatvia . . . . . . . . . . . . . . . . . . . . .2 pmLebanon . . . . . . . . . . . . . . . . . . .2 pmLuxembourg . . . . . . . . . . . . . . . .1 pm

MMalaysia . . . . . . . . . . . . . . . . . . .8 pmMalta . . . . . . . . . . . . . . . . . . . . .1 pmMexico . . . . . . . . . . . . . . . . . . . .6 amMorocco . . . . . . . . . . . . . . . . 12 noon

NNamibia. . . . . . . . . . . . . . . . . . . .2 pmNetherlands (The) . . . . . . . . . . . . .1 pmNew Zealand . . . . . . . . . . .12 midnightNigeria . . . . . . . . . . . . . . . . . . . .1 pmNorway . . . . . . . . . . . . . . . . . . . .1 pm

OOman . . . . . . . . . . . . . . . . . . . . .4 pm

PPanama. . . . . . . . . . . . . . . . . . . .7 amPapua New Guinea. . . . . . . . . . .10 pmPeru . . . . . . . . . . . . . . . . . . . . . .7 amPhilippines . . . . . . . . . . . . . . . . . .8 pmPoland. . . . . . . . . . . . . . . . . . . . .1 pmPortugal . . . . . . . . . . . . . . . . . . .1 pmQQatar. . . . . . . . . . . . . . . . . . . . . .8 am

RRomania . . . . . . . . . . . . . . . . . . .2 pm

international time Zones

AT 12 NOON, GREENwICH MEAN TIME, THE STANDARD TIME ELSEwHERE IS:

PKF Worldwide Tax Guide 2013 VII

Tim

e Zo

nes

Russia - Moscow . . . . . . . . . . . . . . .3 pm St Petersburg . . . . . . . . . . . .3 pm

SSingapore . . . . . . . . . . . . . . . . . .7 pmSlovak Republic . . . . . . . . . . . . . .1 pmSlovenia . . . . . . . . . . . . . . . . . . .1 pmSouth Africa . . . . . . . . . . . . . . . . .2 pmSpain . . . . . . . . . . . . . . . . . . . . .1 pmSweden . . . . . . . . . . . . . . . . . . . .1 pmSwitzerland . . . . . . . . . . . . . . . . .1 pm

TTaiwan . . . . . . . . . . . . . . . . . . . .8 pmThailand . . . . . . . . . . . . . . . . . . .8 pmTunisia . . . . . . . . . . . . . . . . . 12 noonTurkey . . . . . . . . . . . . . . . . . . . . .2 pmTurks and Caicos Islands . . . . . . .7 am

UUganda . . . . . . . . . . . . . . . . . . . .3 pmUkraine . . . . . . . . . . . . . . . . . . . .2 pmUnited Arab Emirates . . . . . . . . . .4 pmUnited Kingdom . . . . . . .(GMT) 12 noonUnited States of America - New York City . . . . . . . . . . . .7 am Washington, D.C. . . . . . . . . .7 am Chicago . . . . . . . . . . . . . . . .6 am Houston . . . . . . . . . . . . . . . .6 am Denver . . . . . . . . . . . . . . . .5 am Los Angeles . . . . . . . . . . . . .4 am San Francisco . . . . . . . . . . .4 amUruguay . . . . . . . . . . . . . . . . . . .9 am

VVenezuela . . . . . . . . . . . . . . . . . .8 am

ZZimbabwe . . . . . . . . . . . . . . . . . .2 pm

PKF Worldwide Tax Guide 2013 1

russia

Currency: Rubles Dial Code To: 7 Dial Code Out: 810 (RUR)

Member Firm:City: Name: Contact Information:Kazan S Nikiforov 843 555 64 94 nikiforov@acg-pkf.ru

Moscow Nadejda Orlova 495 737 53 53 OrlovaN@fbk.ru

Zlatoust Raisa Istomina 35136 5 52 72 ekozlat@chel.surnet.ru

a. taXes payable

FEDERAL TAxES AND LEVIESEnterprises and individuals are liable to taxes and contributions imposed by the Russian Federation and its territorial divisions (republics, regions and provinces).

A foreign legal entity carrying out its business activity through several branches located within the territory of the same municipal entity, Moscow, Saint-Petersburg or territories which are governed by different tax authorities can independently choose one branch for registration for the tax purposes.

COMPANy TAxRussian tax law distinguishes between domestic and foreign enterprises. Domestic enterprises are those which are established under the laws of Russia and are taxed on their worldwide income. Foreign legal entities are subject to Russian profit tax on profits derived from business activities carried on through a permanent establishment in the Russian Federation.

The standard rate of tax is currently 20% of which 2% is normally paid to the federal government and 18% to republican authorities. The tax rate for the share transferred to regional authorities may be as low as 13.5%. 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.

The tax year is the 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.

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.

Under the current tax law, there are no special benefits provided for entities such as religious associations, state and municipal museums, libraries or specialized restoration.

The following allowances are deducted from the taxable base:• profitsreceivedaspaymentstothechartercapital• thecostsofmaintainingcertainsocialfacilities• profitsreceivedasspecial-purposefinancingintheformsof:

(a) foreign financing of capital investments(b) grants for the benefit of culture, sports, recreation, scientific research and

approved research foundations• assetsreceivedbyRussianenterprisesfreeofchargeforthepurposesof

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.

Russia

PKF Worldwide Tax Guide 20132

CAPITAL GAINS TAxCapital gains are treated as ordinary business income and are therefore subject to profits tax according to the general rule.

BRANCH PROFITS TAxThere is no special branch profits tax in Russia.

SALES TAx/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 TAxESState 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 TAxATIONLocal 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.

LOCAL TAxESLocal 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.

OTHER TAxESResident 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.

Russia

PKF Worldwide Tax Guide 2013 3

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.

DEPRECIATIONOnly 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/INVENTORyUnder 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 LOSSESAs discussed above, capital gains and losses are subject to profit tax at regular corporate rates.

DIVIDENDSDividends paid by Russian companies are subject to a final withholding tax whether they are paid to resident or non-resident recipients. From 2011 dividends received by resident companies are subject to a 0% withholding tax rate if:• therecipientholdsatleast50%ofthecapitalofthepayerand• theparticipationhasbeenheldcontinuouslyforthepast365calendardays.This tax rate is 15% if paid to a non-resident company or individual and 9% if paid to a resident company or individual.

INTEREST DEDUCTIONSThin 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.

LOSSESCurrent trading losses may be used to offset profits for the same tax year. Losses may be carried forward for ten years. Losses may be carried to the following tax period without any restrictions.

FOREIGN SOURCED INCOMEForeign 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 will be 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

Russia

PKF Worldwide Tax Guide 20134

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. Domestic and treaty rates are set out in Section I below.

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 9% rate is applied to income in the form of dividends received from share holdings.

All personal income of non-residents, excluding dividends, is taxed at the rate of 30%. For dividends a tax rate 15% is applied.

The following types of income are exempt from tax:• welfarepayments,exceptfortemporarydisability,andcompensationspaidoutin

compliance with legislation currently in force• allkindsofcompensatorypayments,prescribedbylegislation,concernedwith

discharging of labour duties• alimonies• grantsforthepurposeofscience,education,cultureandart,givenbyinternational

and foreign organisations• scholarshipsandsomeothers.

In determining the taxable base, individuals are entitled to the following statutory deductions:

• property-relatedallowance• socialallowance• professionaldeductionsand• standardallowance.

According to the tax legislation:• giftsreceivedfromindividualsareincludedinthelistofitemsofincomethatare

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

• giftsreceivedfromindividualentrepreneursandlegalentitiesareexemptupto RUR 4,000 in a calendar year. The excess is taxable at a rate of 13% for residents and 30% for non-residents

• inheritedpropertyisexemptfromtax.

INSURANCE CONTRIBUTIONSEmployers pay separate insurance contributions on the payroll cost of employing Russian employees. For 2012-2015 the aggregate amount of contributions will be 30%. Special rates are established for certain groups of employers and professions.

Russia

PKF Worldwide Tax Guide 2013 5

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 0 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

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

Russia

PKF Worldwide Tax Guide 20136

Dividends (%)

Interest (%)

Royalties (%)

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 10/15 0 0

Macedonia 10 10 10

Malaysia – (1)/15 (2) 0/15 10/15

Mali 10/15 15 0

Mexico 10 10 10

Morocco 5/10 10 10

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

Russia

PKF Worldwide Tax Guide 2013 7

Dividends (%)

Interest (%)

Royalties (%)

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

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

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

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