As it was mentioned on 28th September 2012 (http://hbcomp.co.uk/about/news_and_mailings/news_jurisdictions/3445/), the Council of Federation of the RF ratified several double taxation avoidance agreements including Latvia. This agreement was signed in Moscow on 20th December 2010. Latvia ratified it on 9th 2011. The most crucial aspects of the agreement are the following:
Firstly, what is also characteristic for the ratified agreement with Switzerland, provisions on tax data exchange, providing cooperation during taxation, preventing of fraudulent schemes, which are aimed at receiving of tax profit (conduit deals) were included into the agreement with Latvia.
Secondly, the residents of the Russian Federation who own the capital and immovable property taxable in Latvia have a right to tax deduction in the size of the taxes payed. The same rule also refers to the residents of Latvia who payed taxes on the territory of the Russian Federation.
Thirdly, income from sell of stocks, shares and units the half of which (50%) are secured by real estate can be taxed in the place of property situation.
Fourthly, the rates of taxes while paying the dividends, interest and royalty have been agreed:
Income |
Tax rate |
Dividends |
5% (company owns 25% of capital of the company which pays dividends and the sum of investments is not less than 75,000 USD); 10% (in other cases) |
Interest |
5% (for interbank credits); 10% (in other cases) |
Royalty |
5% |
This tax agreement, undoubtedly, improves the investment climate both in the Russian Federation and Latvia and also prescribes the fair taxation of residents of both countries.
Akhmetova Julia ( Paralegal of Moscow office )
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