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Christian Lyk

ABOUT THE AUTHOR

Christian Lyk graduated from the University of Berne and qualified as Attorney at Law and graduated as a Master of Laws (LL.M International Taxation). He joined KPMG in 1998 where he became Head of the Tax Department in 2002. In 2005 Christian Lyk joined Kendris, becoming Head of Tax and Legal Department (2006 – 2015). Since 2009 he has been a member of the Executive Committee of Kendris Ltd. and both partner and CEO since 2018. He has been FATCA Responsible officer of Kendris Group and Head CRS Reporting. He has held a number of tax-related functions at various bodies such as SATC (Swiss Association of Trust Companies), the Swiss Institute of Taxation and has been a member of the teaching staff at the University of Lucerne.
Update on Partial Suspension of the Double Tax Treaties with “Unfriendly States”

by Christian Lyk | Aug 9, 2023 | Regulatory

The case

​Yesterday, the President of the Russian Federation both signed and published new Decree ‘On suspension by the Russian Federation of certain provisions of the Double Tax Treaties’ No. 585 (the “Decree No. 585”).

The list of partially suspended Double Tax Treaties (the “DTTs”) includes 38 “Unfriendly States”: Albania; Australia; Austria; Belgium; Bulgaria; the Czech Republic; Canada; Croatia; Cyprus; Denmark; Finland; France; Germany; Greece; Hungary; Iceland; Ireland; Italy; Japan; Lithuania; Luxembourg; Macedonia; Malta; Montenegro; New Zealand; Norway; Poland; Portugal; Romania; Singapore; Slovakia; Slovenia; South Korea; Spain; Sweden; Switzerland; the UK and Northern Ireland; and the US.

Decree No. 585 comes into force immediately and suspends the key provisions of the DTTs regulating taxation of income, while certain provisions such as tax credits, exchange of tax information, etc. remain in force. Decree No. 585 does not have a retrospective effect, and the tax rates that have already been applied before August 8, 2023 will not be recalculated. At the same time, Decree No. 585 does not specify any date as to when the full effect of the DTTs might be restored.

Source: ALRUD Law Firm, Moscow

The commentary

We recommend that international groups with branches in Russia assess the new tax situation and the resulting tax risks with their advisors sooner rather than later.

 

This publication has been prepared solely for information purposes and is does not constitute a recommendation, a solicitation, or an offer. The information on which this publication is based has been obtained from sources that we believe to be reliable and in good faith, but we have not independently verified such information and no representation or warranty, express or implied, is made as to its accuracy. All expressions of opinion are made as of the date of publication and may be subject to change without notice. k-flash and all related affiliates accepts no liability or responsibility whatsoever for any consequential loss of any kind arising out of the use of this publication or any part of its contents. The use of this publication should not be regarded as a substitute for the exercise by the recipient of his or her own judgment. This publication is not directed to any person in any jurisdictions that prohibit such publication.
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