The UK’s tax, payments and customs authority (HMRC) has announced that the 1994 tax treaty with Russia will be suspended starting 6 April 2025 for income tax and capital gains tax. The suspension will extend to corporation tax and all other taxes from 1 April 2025.
This announcement was made by UK HMRC on 4 February 2025.
Following Russia’s unlawful action to suspend material provisions of the 1994 UK-Russia Double Taxation Convention in August 2023, the UK continued to honour its treaty obligations. The UK requested that Russia come back into compliance with its international legal obligations. As it has not done so, the UK has now notified Russia of its intention to suspend the Convention.
The UK will revoke the legislation which gives effect to the Convention in UK law. The Convention will cease to have effect from:
- 6 April 2025 for Income Tax and Capital Gains Tax
- 1 April 2025 for Corporation Tax
Domestic tax law will be applicable without reference to the treaty from that time. The terms of the treaty will continue to apply for earlier periods.
Should Russia come back into compliance with its treaty obligations, it will be possible to enact new legislation to give effect to the treaty once again in UK law.
