According to the Germany-Russia Income and Capital Tax Treaty, the Finance Ministry has declared a Letter 03-08-RZ/38351 describing the tax treatment applicable to royalties paid by a Russian resident to a German limited liability partnership and was issued on August 4, 2014. The MoF figured out that a limited liability partnership created on the basis of the German legislation is not deemed to be a separate legal person. If tax residence certificate for all the partnership members are submitted with a document to the Russian payer together confirming that the income is taxed in Germany then according to the Tax Treaty, a limited liability partnership formed under the German legislation may claim release in Russia.
Related Posts
Russia: VAT return for first quarter must be filed using revised form
The Russian Federal Tax Service has reminded taxpayers, on 17 April 2026, that the VAT return for the first quarter of 2026 must be submitted using the updated form, with the deadline for submission set for 27 April 2026. The relevant order of
Read MoreRussia, China sign tax cooperation memorandum
Russia's Federal Tax Service announced on 21 April 2026 that Russia and China have formalised their collaboration through a Memorandum of Understanding signed by Daniil Egorov, Head of Russia's Federal Tax Service, and Hu Jinglin, Head of China's
Read MoreFinland: Government approves suspension of law enforcing Russia tax treaty
Finland’s government approved a proposal to suspend the domestic implementing act of the Finland–Russia Income Tax Treaty (1996), as amended on 16 April 2026. The proposal has been submitted to parliament for consideration. Finland has
Read MoreRussia urges individuals to submit CFC notifications before April deadline
The Russian Federal Tax Service has issued a reminder that individuals are required to submit the annual notification on controlled foreign companies (CFCs) for the 2025 tax year by 30 April 2026. This obligation applies regardless of the financial
Read MoreRussia: MoF confirms Finland’s suspension of tax treaty
The Russian Ministry of Finance (MoF) announced on 26 March 2026, citing Note No. VN/1187/2026-UM-10, issued by the Embassy of Finland in Moscow on 13 March 2026, states that the Government of Finland will fully suspend the Agreement between the
Read MoreRussia updates reporting rules for foreign accounts, electronic payments
Russia’s government Resolution No. 305, published in the Official Gazette on 24 March 2026, introduces amendments to reporting requirements for resident legal entities regarding foreign accounts and electronic payment instruments (EPI). The decree
Read More