The Hong Kong Inland Revenue Department (IRD) has released the synthesised text of the tax treaty with Russia, as affected by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
This synthesised text incorporates the reservations and notifications (MLI positions) provided by both countries.
The original legal documents of the tax treaties and the MLI remain authoritative and are the applicable legal texts.
The MLI applies to the 2016 Hong Kong-Russia tax treaty:
- In Hong Kong:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occur on or after 1 April, 2024; and
- with respect to all other taxes levied by Hong Kong, for taxes levied with respect to taxable periods beginning on or after 1 April, 2025.
- In Russia:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January, 2025; and
- with respect to all other taxes levied by Russia, for taxes levied with respect to taxable periods beginning on or after 1 January, 2025.
