Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.
ARTICLE 28
Entry into Force
(1) This Agreement shall be ratified. The ratification documents shall be exchanged as soon as possible.
(2) This agreement shall enter into force on the day of exchange of the instruments of ratification and shall be applied:
- (a) to taxes levied at source on dividends, interest and royalties on the tax that is paid on or after 1st of January of the calendar year that follows the year in which the Agreement has come into force;
- (b) as regards remainder of taxes, to the taxes levied for the period beginning 1st January of the calendar year that follows the year in which the Agreement has come into force.
(3) With the entry into force of this Agreement between the Federal Republic of Germany and the Russian Federation, the Agreement dated 24th November, 1981 between the Federal Republic of Germany and the Union of Soviet Socialistic Republics for the avoidance of double tax on income and capital stands terminated:
- (a) in case of taxes levied by way of deductions at source on dividends, interest and royalties to the taxes that will be paid on or after 1st January of the calendar year that follows the year in which this Agreement has entered into force;
- (b) in case of all other taxes, to the taxes that were levied for the period starting 1st January of the calendar year that follows the year in which this agreement has entered into force.