Russia and Hong Kong double tax treaty will apply from 1st January 2017 in Russia and from 1st April 2017 in Hong Kong.


Treaty Benefits and Tax Incentive

The treaty shall open new opportunities for Russian and foreign investors utilising treaty benefits and Russian tax incentives (participation exemption, Eurobond withholding tax exemption, CFC rules).


The treaty is applied with following conditions:

Interest – 0%

Dividends – 5% under the condition that the recipient of the dividends is a company (other than partnership), holds 15% of the capital; all other cases 10%

Royalties – 3%

Capital Gains – 0% as general rule; 20% – capital gains derived from alienation of immovable property, capital gains derived from alienation of shares of a company deriving more than 50% of its assets value directly or indirectly form immovable property , exemption applies in case of companies listed on the Stock Exchange.

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