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The Convention between the Russian Federation and Belgium for the avoidance of double taxation


On May 23rd, 2018 Russia has ratified the Convention with Belgium for the avoidance of double taxation. The parties have entered into this agreement even in 1995. However, in response with changing in the legislation of both countries it was made decision about reasonability to adopt the new Convention instead of a protocol amending the existing Agreement.

The Convention covers on the income tax and capital of legal entities and individuals who have place of residence, permanent stay, place of management in Russian Federation or in the Kingdom of Belgium.

In accordance with the provisions of the Convention taxation of income (profit) from entrepreneurial activity is made if a person conducts business in another country with the help of a permanent establishment located in it but only in part related to this permanent establishment.

Additionally the dividend tax rate will be 5% if the company owns at least 10 percent of the capital of the company which is paying dividends within 12 months. At the same time the paid amount must be at least 80,000 euros or an equivalent amount in rubles in the authorized capital.

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