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Amending Protocol to Tax Treaty between the Netherland and Russia Under Negotiation

11 September 2020

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Treaty Development

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Netherlands-Russia

Officials from the Netherlands and Russia have reportedly begun negotiation for an amending protocol to the 1996 tax treaty between the two countries to provide for a minimum withholding tax rate of 15% on dividends and interest. Under the current provisions of the Russia-Netherlands treaty, interest is exempt from withholding and a 5% withholding tax rate applies if the beneficial owner is a company directly holding at least 25% of the paying company's capital and has invested at least 75,000 ECU or its equivalent (otherwise, a 15% rate applies).