The Council of Federation ratified double taxation avoidance agreements with Latvia, Argentina and Switzerland

28.09.2012

On 26^th September 2012 the Council of Federation ratified double taxation avoidance agreements with Latvia and Argentina and the Protocol to the analogical agreement with Switzerland.

As far as novelties relating to the treaty with Switzerland were highlighted by us yesterday (), the treaties with Latvia and Argentina should be considered in details.

Firstly, these agreements regulate the procedure of income taxation of residents from the contracting countries (income from the entrepreneurial activity, from dividends, interest, immovable property, international sea transportation, etc.). For instance, taxation of income from the entrepreneurial activity is carried out in the state where the permanent establishment is situated through which a person conducts business.

Secondly, the procedure of considering the complaints and appeals of taxpayers, dispute resolution, data exchange between the competent bodies are regulated by the agreements.

On the basis:

http://www.council.gov.ru/print/inf_ps/chronicle/2012/09/item20332.html

Expert’s opinion

The forced ratification by the Russian Federation of the intergovernmental double taxation avoidance agreements is explained by the active participation of the state in such a huge international organization as FATF (Financial Action Task Force on Money Laundering). Furthermore, the Russian Federation refers to the countries that had introduced the tax standards adopted by the OECD (Organization for Economic Co-operation and Development), consequently tries to comply with its status. It is also important to notice that the Russian Federation in connection with entering in the WTO (World Trade Organization) on 22nd August 2012 launched negotiations with the OECD that could be finished in 2013 about the membership of the Russian Federation.

Akhmetova Julia ( Paralegal of Moscow office Honest & Bright Company)