In an address to the nation on 25 March 2020, the President of Russia announced a number of tax initiatives, one of which concerns the taxation of dividends paid from Russia that may have a major impact on the tax treaty system.The President said in his speech that “all income payments (in the form of interest and dividends) that flow out of Russia to offshore jurisdictions must be taxed appropriately.” It is therefore proposed that “… for those who move their dividend income out of the country into foreign accounts, the rate of tax on such dividends should be set...