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Update – Protocol to Tax Treaty between Austria and Russia

15 June 2018

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Treaty Development

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Austria-Russia

The protocol to the 2000 income and capital tax treaty between Austria and Russia was signed on 5 June 2018. The protocol is the first to amend the treaty and includes the following main changes: Article 2 (Taxes Covered) is amended with respect to Russian taxes; Article 10 (Dividends) is amended with the removal of the minimum USD 100,000 participation value requirement for the 5% reduced withholding tax rate where the beneficial owner is a company directly holding at least 10% of the paying company's capital; Article 10 (Dividends) is amended with the addition of payments on units of the...