16 August 2023

Russia suspends the majority of articles of the double tax treaty between Switzerland and Russia with immediate effect

  • Articles
  • Tax
  • Employment / Immigration
  • Structuring / Relocation
  • Trade / Logistics / Competition

By presidential decree of 8 August 2023, the Russian government has suspended numerous articles of double tax treaties with more than 30 countries - the double tax treaty between Russia and Switzerland («DTT CH-RUS») is also affected.*

  • Dr. Hagen Luckhaupt

    Senior Tax Advisor

  • Andreas Müller

    Tax & Legal Partner

  • Leila Sonderegger

    Tax Consultant

Affected articles

The Presidential Decree of 8 August 2023 suspended Articles 5 to 22, 24 and 25b of the DTT CH-RUS. In addition, Articles 3 to 6 of the Protocol to the DTT CH-RUS have been suspended.

Thus, all allocation norms, which form the core of a double tax treaty, are currently suspended. This step was justified by alleged "violations of the legitimate economic and other interests of the Russian Federation".

Switzerland's position

The SIF has reportedly taken note of the Presidential Decree of 8 August 2023, but intends to continue applying the DTT CH-RUS.

Do you have any questions? Do you need assistance? MME will be happy to assist you.

*Agreement between the Swiss Confederation and the Russian Federation on the Avoidance of Double Taxation in the Field of Income taxes and on Capital taxes of 15 November 1995 (SR 0.672.966.51)
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