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Germany - Russia Tax Treaty (as amended by 2007 protocol) — Orbitax Tax Hub

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.


Taxes Covered

(1) This Agreement shall apply to tax on income and on capital, imposed according to the tax laws of each Contracting State, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital or on a part of the income or of capital, inclusive of tax on the capital gains from the alienation of movable or immovable property.

(3) The existing taxes to which the Agreement shall apply are in particular:

  • (a) In the Russian Federation:
    • (i) tax on income of enterprises and organizations;
    • (ii) income tax of individuals;
    • (iii) capital tax of enterprises; and
    • (iv) capital tax of individuals;
  • (Which shall be referred to hereinafter as "Russian tax");
  • (b) In the Federal Republic of Germany:
    • (i) income tax, (Einkommensteuer);
    • (ii) corporate tax, (Körperschaftsteuer);
    • (iii) capital tax, (Vermögensteuer);
    • (iv) professional tax (Gewerbesteuer); and
    • (v) solidarity surcharge (Solidaritätszuschlag);
  • (Which shall be referred to hereinafter as "German tax").

(4) The agreement shall also apply for all taxes of a similar or identical nature, which may be imposed, after the signing of this Agreement, in addition to, or in place of, the existing taxes. The competent authority of the Contracting States shall notify each other, if found necessary, of changes that have been made in their respective tax laws.