New Protocol to the Cyprus / Russian Tax Treaty
On February 15, 2012 the Russian Duma ratified the Protocol (the “Protocol”) to the Double Tax Treaty between Cyprus and Russia dated December 05, 1998 (the “Treaty”) while Cyprus had ratified the Protocol in September 2011. The text of the amending Protocol can be accessed below.
The Protocol came into force on 02 April 2012. Its provisions will apply as of January 01, 2013 whilst some provisions will be effective as of January 01, 2017.
The crucial consequence of the Protocol is that Cyprus has been removed from Russia’s blacklist of states and territories. Among other, this will enable Russian companies to benefit from Russia’s participation exemption on dividends received from Cypriot companies.
As regards the exchange of information provisions in the Protocol, etc., which have been subject to considerable press coverage, in fact, these do not affect the current legal position in Cyprus which, in any event, is according to “Law 72(I)/2008”.
The text of the amending Protocol can be accessed here.