Doing Business in Russia
Doing Business in Russia 49
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in the Russian company and (ii) is taxed in France but is
exempt with respect to dividends (i.e. has a participation
exemption). A 10% rate applies if only one of the
requirements is fulfilled; otherwise, 15%.
Germany: 5% on dividends - - this rate applies if the
German company owns at least 10% of the capital in
the Russian company and the holding value is at least
EUR80,000; otherwise, 15%.
Greece: 5% on dividends - this rate applies if the
recipient company (not a partnership) directly owns at least
25% of the capital in the Russian company; otherwise,
10%.
Iceland: 5% on dividends
- this rate applies if the
recipient company (not a partnership) owns at least 25%
of the capital in the Russian company and the value of the
capital investment is at least USD100,000; otherwise,
15%.
India: a 0% tax rate on interest applies to interest paid to
the government, its local authorities, public bodies or the
central bank; otherwise, 10%.
Indonesia: a 0% tax rate on interest applies to interest
paid to the government, its local authorities, political
subdivisions, the central bank; otherwise, 15%.
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Iran: 5% on dividends - this rate applies if the recipient
company (not a partnership) directly owns at least 25% of
the capital in the Russian company; otherwise, 10%.0%
on interest applies to interest paid to the contracting state,
its local authorities, public bodies or the national banks;
otherwise, 7.5%.
Israel: 0% on interest applies to interest paid to the
government, local authorities and the central bank;
otherwise, 10%.
Italy: 5% on dividends this rate applies if the recipient
company directly owns at least 10% of the capital in
the Russian company and the holding value is at least
USD100,000; otherwise, 10%.
Japan: a 0% tax rate on interest applies to interest paid to
the government, its local authorities, public bodies or the
central bank; otherwise, 10%. 0% on royalties this rate
applies to copyright royalties; otherwise, 10%.
Kazakhstan: a 0% tax rate on interest applies to interest
paid to the contracting state, local authorities or public
bodies; otherwise, 10%.
South Korea (Rep.): 5% on dividends - this rate applies
if the recipient company owns directly at least 30% of the
capital in the Russian company and the value of the holding
is at least USD 100,000; otherwise, 10%.
Kuwait: 0% on dividends - this rate applies if dividends
are distributed to the government, local authorities, public
entities, the central bank, and public financial institutions;
otherwise, 5%.
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Kyrgyzstan: a 0% tax rate on interest applies to interest
paid to the government, its local authorities, public bodies
and the central bank; otherwise, 10%.
Latvia: 5% on dividends — this rate applies if the recipient
company (other than a partnership) owns directly at
least 25% of the capital in the Russian company and the
capital invested exceeds USD75,000; otherwise, 10%.
5% on interest applies to the interest on loans of any kind
granted by a bank or other financial institution of one of the
contracting states to a bank or other financial institution of
the other contracting state; otherwise, 10%.
Lebanon: 0% on interest applies to interest paid to the
government, its local authorities, and public bodies;
otherwise, 5%.
Lithuania: 5% 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 and the
value of the capital investment is at least USD100,000;
otherwise, 10%.0% on interest applies to interest paid to
the government, its local authorities, public bodies, and the
central bank; otherwise, 10%. 5% on royalties- this rate
applies to equipment rentals; otherwise, 10%.
Luxembourg: 5% on dividends — this lower rate applies
if the Luxembourg recipient directly owns at least 10% of
the capital in the Russian company and the holding value is
at least EUR80,000 or its equivalent in national currency;
otherwise, 15%.
Malaysia: 15% on dividends - this rate applies to profits
of joint ventures; otherwise, the domestic rate applies;
there is no reduction under the treaty. 0% on interest
applies to interest paid to the government and the central
bank; otherwise, 15%. 10% on royalties. this rate applies
to authors' rights and equipment rentals; 15% on royalties
this rate applies to films and broadcasting programs and
copyrights on items of literature or art.
Mali: 10% on dividends this rate applies if the value of
the holding is at least FRF1 million; otherwise, 15%.0%
on interest applies to interest paid by the government
or its local authorities, paid to the government, its local
authorities or the central bank; otherwise, 15%.
Malta: 5% on dividends this rate applies if the recipient
company owns at least 25% of the capital in the Russian
company and the total amount of investments into
capital is at least EUR 100,000; otherwise, 10%. The zero
rate applies to dividends paid to a pension fund, if such
dividends are derived from investments made using the
assets of that pension fund.
Mexico: 0% on interest-
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this lower rate applies to
interest paid to the government, the central bank and
public bodies, and interest paid in respect of a loan for
a period of at least three years granted, guaranteed or
insured by specified banks; in other cases, 10%.
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