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Amending Protocol to Tax Treaty Between Luxembourg and Russia has Entered into Force

09 March 2021

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Treaty Development

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Luxembourg-Russia

The Russian Ministry of Finance has announced that the amending protocol to the 1993 income and capital tax treaty between Luxembourg and Russia entered into force on 5 March 2021. The protocol, signed 6 November 2020, is the second to amend the treaty and includes the following changes: Paragraph 2 of Article 10 (Dividends) is replaced, providing for a standard withholding tax rate of 15%; A new paragraph 3 is added to Article 10 (Dividends), providing for a reduced withholding tax rate of 5% if the beneficial owner of the dividends: is an insurance undertaking or a pension fund; is...