The Australian Taxation Office (ATO) has published the synthesized text of the 2000 income tax treaty with Russia as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized text was prepared on the basis of the reservations and notifications (MLI positions) provided by Australia and Russia on the date of deposit of their MLI ratification instruments. The sole purpose of the text is to facilitate the understanding of the application of the MLI to the Agreement and it does not constitute a source of law. The authentic legal texts of the Agreement and the MLI take precedence and remain the legal texts applicable.
The MLI applies for the 2000 Australia-Russia tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021;
- with respect to all other taxes levied by Australia, for taxes levied with respect to taxable periods beginning on or after 30 November 2020; and
- with respect to all other taxes levied by the Russian Federation, for taxes levied with respect to taxable periods beginning on or after 1 January 2021.
Click the following link for the ATO's webpage on the BEPS MLI for more information.