Russian Federation
A. Progress in the implementation of the minimum standard
The Russian Federation has 85 tax agreements in force, as reported in its response to the Peer Review questionnaire. Thirty-six of those agreements comply with the minimum standard.
The Russian Federation signed the MLI in 2017 and deposited its instrument of ratification on 18 June 2019. The MLI entered into force for Russian Federation on 1 October 2019. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
The Russian Federation has not listed its agreements with Brazil, Germany, Namibia, North Macedonia and Switzerland under the MLI. These agreements will therefore not, at this stage, be modified by the MLI. North Macedonia has listed the agreement with the Russian Federation under the MLI. North Macedonia has listed its agreement with Russian Federation under the MLI.
The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect. The Russian Federation reserved the right to delay the entry into effect of the provisions of the MLI until the Russian Federation has completed its internal procedures for this purpose with respect to each of its listed agreements.1 The Russian Federation notified that it completed its internal procedures for the entry into effect of the MLI with respect to its agreements with Australia, Austria, Belgium (old), Canada, Denmark, Finland, France, Iceland, India, Ireland, Israel, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Qatar, Serbia, Singapore, the Slovak Republic, Slovenia, Ukraine, the United Arab Emirates and the United Kingdom on 30 April 2020, and with respect to its agreements with Cyprus*, the Czech Republic, Indonesia, Kazakhstan, Korea, Portugal and Saudi Arabia on 26 November 2020.
The Russian Federation indicated in its response to the Peer Review questionnaire that steps had been taken (other than under the MLI) to implement the minimum standard it the agreements with Brazil, Germany and Switzerland.
The Russian Federation further indicated in its response to the Peer Review questionnaire that the agreements with Namibia and North Macedonia do not give rise to material treaty-shopping concerns for the Russian Federation.
The Russian Federation is implementing the minimum standard through the inclusion of the preamble statement and the PPT combined with the LOB.2
B. Conclusion
The Russian Federation is encouraged to complete (and notify that it has completed) its internal procedures for the entry into effect of the MLI with respect to its agreements that are covered tax agreements under the MLI and for which no such notification has yet been made.
North Macedonia as listed its agreement with Russian Federation under the MLI, which amounts to a request to implement the minimum standard.
← 1. The reservation was made under Article 35(7)(a) of the MLI.
← 2. For its agreements listed under the MLI, the Russian Federation is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). The Russian Federation has also adopted for the simplified LOB under Article 7(6) of the MLI.