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Russia-United Kingdom-Cayman Islands-B Virgin Isl-Isle Of Man-Jersey-Guernsey-Gibraltar

18 November 2019

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Russia Clarifies Tax Treaty with UK Does Not Cover UK Crown Dependencies and Overseas Territories

Russia's Ministry of Finance recently published Guidance Letter No. 03-08-05/80345 on the taxation of income of a resident company of the Cayman and British Virgin Islands, the Isle of Man, the Channel Islands (including Jersey and Guernsey), and Gibraltar from sources in Russia. In particular, the letter addresses whether the provisions of the 1994 Russia-UK income and capital tax treaty may be applied in respect of these UK Crown Dependencies and Overseas Territories.

The letter notes that these territories are not included within the definition of the "United Kingdom" as provided in paragraph (1)(a) of Article 3 (General Definitions) of the Russia-UK tax treaty. As such, the taxation of income from Russian sources derived by a tax resident company in these territories must be carried out in the manner provided for in Chapter 25 (Corporate Income Tax) of the Russia Tax Code, i.e., the Russia-UK tax treaty does not apply.

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