Doing Business in Russia

Doing Business in Russia 51 the capital investment is at least USD100,000; otherwise, 15%. - Singapore: 5% on dividends - this rate applies if the recipient of the dividends is the government of the other contracting state or company which directly owns at least 15% of the share capital in the company paying dividends and has invested in this company at least USD100,000 or its equivalent in another currency; otherwise, 10%. A 0% tax rate on interest applies to interest paid to the government of the other contracting state; otherwise, 7.5%. ― South Africa: 10% on dividends this rate applies if the recipient company owns at least 30% of the capital in the Russian company and has directly invested in this company at least USD100,000; otherwise, 15%. A 0% tax rate on interest applies to interest paid by public bodies; otherwise, 10%. Spain: 5% on dividends. this 5% rate applies if (i) the Spanish company has invested at least EUR100,000 in the Russian company and (ii) the dividends are exempt in Spain. A 10% rate applies if only one of the conditions is met; otherwise, 15%. 0% on interest - this lower rate applies to long-term loans (minimum 7 years) granted by credit institutions residing in a contracting state; otherwise, 5%. Sri Lanka: 10% on dividends this rate applies if the recipient company (other than a partnership) directly owns at least 25% of the capital in the Russian company; otherwise, 15%. 0% on interest - this lower rate applies to interest paid to the government, its local authorities, public bodies, the central bank; otherwise, 10%. Sweden: 5% on dividends - this rate applies if a Swedish company (other than a partnership) owns 100% of the capital in a Russian company (or in the case of a joint venture, at least 30% of the capital in the joint venture) and foreign capital invested exceeds USD100,000 or its equivalent in national currencies; otherwise, 15%. Switzerland: 0% on dividends. this rate applies if dividends distributed to a pension fund (or similar institution), the government, any political subdivision, local authority or the central bank; a 5% rate on dividends applies if the Swiss company (other than a partnership) directly owns at least 20% of the capital in the Russian company and the holding value exceeds CHF200,000 or its equivalent in another currency; otherwise, 15%. - Syria: 0% on interest — this lower rate applies to interest paid to the government, its local authorities, and public bodies; otherwise, 10%. 4.5% on royalties - this rate applies to films and broadcasting programs, and to recordings for radio/TV broadcasting; 13.5% on royalties ―this rate applies to copyrights on items of literature, art or science; 18% - this rate applies to patents, trade mark design or models, plans, secret formulae/processes, any computer software programs, or for information concerning industrial, commercial or scientific experience. - = - Tajikistan: 5% on dividends this rate applies if the recipient company directly owns at least 25% of the capital in a Russian company; otherwise, 10%. A 0% tax rate on interest applies to interest paid to the government, its local authorities, public bodies or the central bank; otherwise, 10%. Thailand: A 0% tax rate on interest applies to interest paid to the government, public bodies, the central bank, the Export-Import Bank of Thailand; a 10% tax rate on interest applies to interest paid to financial institutions. The domestic rate applies in other cases; there is no general reduction under the treaty. - Turkey: A 0% tax rate on interest applies to interest paid to the government or the central bank, or to the Turkish Eximbank; otherwise, 10%. UAE: 0% on dividends - this rate applies only if the recipient is a financial or investment institution. A 0% tax rate on interest - this rate applies only if the recipient is a financial or investment institution. The treaty does not cover royalties. UK: 10% on dividends - applies if dividends in the hands of the recipient company are subject to tax. Ukraine: 5% on dividends. - this rate applies if the holding value is at least USD50,000; otherwise, 15%. A 0% tax rate on interest applies to interest paid to the government or the central bank; otherwise, 10%. _ USA: 5% on dividends this rate applies if the recipient company owns at least 10% of the capital or voting power in the Russian company; otherwise, 10%. Uzbekistan: A 0% tax rate on interest applies to interest paid to the government, its local authorities or the central bank; otherwise, 10%. Venezuela: 10% on dividends - this rate applies if the recipient company (other than a partnership) directly owns at least 10% of the capital in the Russian company and the holding value is at least USD 100,000; otherwise, 15%. A 0% tax rate on interest applies to interest paid by (or to) the government, its local authorities, the central bank or public bodies. If the interest is paid on a loan granted/guaranteed by a financial institution of a public character with the objective of promoting exports and development, then a 5% tax rate on interest applies to interest paid to the bank; otherwise, 10%. 10% on royalties - this rate applies to fees for technical services; otherwise, 15%. Vietnam: 10% on dividends - this rate applies if the recipient company has invested in the capital of the Russian company at least USD10 million; otherwise, 15%. ©2016 KPMG. All rights reserved.

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