New DTT between Russia and Japan

AO UniCredit Bank
Thu, 28/09/2017

A new double taxation treaty with Japan will replace a previous convention dating back to 1986                                                                                                                

In September, the governments of the Russian Federation and Japan signed the Convention for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance.

The Convention establishes the following DTT rates with respect to dividend and interest payments:

  • In cases where the dividends are beneficially owned by a company holding at least 15% of the voting power for 365 days the tax rate is equal to 5% and 10% in all other cases. Dividends from a company are taxed at 15% if at least 50% of share value is derived from immovable property.
  • Interest payments are tax exempted and interest calculated based on sales, profits, revenue and other cash flows of a debtor is taxed at a maximum of 10%.


Yuliya Umnova

Head of Product  Development and Relationship Management

GSS Russia